IN RE: the Civil Commitment of T.C. (2026)

MEMORANDUM DECISION

Case Summary

[1] T.C. brings this appeal and challenges his involuntary temporary commitment to Sandra Eskenazi Mental Health Center (“Center”). T.C. claims the evidence is insufficient to show that his commitment was appropriate. Concluding that clear and convincing evidence supports T.C.’s involuntary temporary commitment, we affirm.

Issue

[2] T.C. raises one issue, which we restate as whether the evidence is sufficient to support T.C.’s involuntary temporary commitment.

Facts

[3] T.C. is thirty-three years old and speaks Burmese. T.C. was admitted to Center three times for catatonia.¹ From November 1, 2025, to November 20, 2025, T.C. voluntarily admitted himself. Dr. Jamie Ahmed began treating T.C. on November 3, 2025. In diagnosing T.C. with catatonia, Dr. Ahmed observed that T.C. spoke very little, took a long time to answer questions, appeared indecisive,² and exhibited negativism,³ and ambitendency,⁴ and, when T.C. was at his worst, T.C. did not react to his environment, care for his hygiene, or eat. Dr. Ahmed believed T.C.’s catatonia was related to schizophrenia, although she did not diagnose T.C. with schizophrenia. According to Dr. Ahmed, catatonia interferes with the ability to diagnose a patient because of the patient's inability to converse.

[4] In addition to T.C.’s catatonic symptoms, Dr. Ahmed observed that T.C. exhibited paranoia. She observed this paranoia when T.C. was on the highest dose of Ativan and was better able to communicate. Dr. Ahmed treated T.C.’s catatonia with Ativan and began to taper the medication while T.C. was admitted. On November 20, 2025, T.C. was released with further instructions to taper Ativan, and Dr. Ahmed did not believe that T.C. was gravely disabled or dangerous at that time.

[5] T.C. was admitted to Center for the second time after visiting the emergency room on January 9, 2026. T.C. was voluntarily admitted with the goal of reducing his medication, Ativan, to a safe amount. Dr. Ahmed and T.C. agreed that T.C. would be released on February 4, 2026, into the care of T.C.’s brother (“Brother”). When Brother arrived on February 4, however, Brother told Dr. Ahmed that he could not care for T.C. while T.C. was in his current state.

[6] T.C.’s third admission was an emergency detention on February 4, 2026, because Dr. Ahmed did not believe T.C. could care for himself. Center filed an application for emergency detention on February 4, 2026, and the trial court granted the application on February 5, 2026. Also on February 5, 2026, Center filed a petition to temporarily commit T.C., in which it alleged that T.C. was suffering from catatonia and was gravely disabled.

[7] While hospitalized, T.C. voluntarily accepted medication with encouragement, and T.C. was eating an adequate amount, which Dr. Ahmed attributed to the medication. T.C.’s symptoms were not completely responding to his treatment, and, when Dr. Ahmed tried to taper T.C.’s medication, Ativan, T.C.’s symptoms worsened. Dr. Ahmed recommended tapering off Ativan and beginning electroconvulsive therapy (“ECT”).⁵ Dr. Ahmed testified that a patient generally receives treatments three times a week and 6-12 treatment sessions overall. Although ECT has its own risks,⁶ Dr. Ahmed recommended ECT because Ativan has high risks for physical dependency with long-term use, T.C.’s symptoms were worsening, T.C.’s symptoms had an incomplete response to Ativan, and ECT was more likely to be effective than Ativan. Dr. Ahmed considered alternatives to ECT, but she indicated that, “when you have symptoms that are severe enough that Ativan is not completely effective[,] then the potential for [ ] other medications to work is slim.” Tr. Vol. II p. 13.

[8] ECT would require multiple treatments. Dr. Ahmed recommended that T.C. be transferred to another hospital for ECT with the possibility of outpatient ECT. Dr. Ahmed believed this was the least restrictive means of treating T.C.

[9] Dr. Ahmed last examined T.C. on the morning of the hearing concerning his involuntary commitment. Dr. Ahmed believed that T.C. could not care for himself because T.C. failed to eat when he last left the hospital. Dr. Ahmed also believed T.C. would struggle to navigate the bus system or other means of transportation, and Dr. Ahmed believed T.C. would struggle to find housing and shelter if discharged.

[10] A fact-finding hearing regarding the petition for temporary involuntary commitment was held on February 18, 2026. At the hearing, T.C. wanted to testify, but, when the trial court attempted to place him under oath, T.C. was unable to respond. The trial court found by clear and convincing evidence that T.C. was suffering from a mental illness, was gravely disabled, and “in need of care, custody, and treatment” at Center. Appellant's App. Vol. II p. 47. Further, Center was the least restrictive environment for T.C.’s treatment and stabilization. This commitment was not to exceed ninety days.⁷ T.C. now appeals.

Discussion and Decision

[11] T.C. appeals his involuntary temporary commitment. “ ‘[T]he purpose of civil commitment proceedings is dual: to protect the public and to ensure the rights of the person whose liberty is at stake.’ ” Civ. Commitment of T.K. v. Dep't of Veterans Affs., 27 N.E.3d 271, 273 (Ind. 2015) (quoting In re Commitment of Roberts, 723 N.E.2d 474, 476 (Ind. Ct. App. 2000)). To satisfy the requirements of due process, the facts justifying an involuntary commitment must be shown “ ‘by clear and convincing evidence ․ [which] not only communicates the relative importance our legal system attaches to a decision ordering an involuntary commitment, but ․ also has the function of reducing the chance of inappropriate commitments.’ ” Id. (quoting Commitment of J.B. v. Midtown Mental Health Ctr., 581 N.E.2d 448, 450 (Ind. Ct. App. 1991), trans. denied); Ind. Code § 12-26-2-5(e).

[12] We affirm a civil commitment if:

considering only the probative evidence and the reasonable inferences supporting it, without weighing evidence or assessing witness credibility, a reasonable trier of fact could find [the necessary elements] proven by clear and convincing evidence. Probative evidence is that which tends to prove or disprove a point in issue. And [i]n order to be clear and convincing, the existence of a fact must be highly probable.

A.D. v. Cmty. Fairbanks Behav. Health, 274 N.E.3d 463, 464 (Ind. 2026) (quoting J.W. v. Cmty. Fairbanks Behav. Health, 260 N.E.3d 946, 951 (Ind. 2025)) (internal quotation marks and citations omitted; insertions in original).

[13] For involuntary temporary commitments of not more than ninety days, the petitioner must prove by clear and convincing evidence that the individual is “mentally ill and either dangerous or gravely disabled” and the commitment is “appropriate.” Ind. Code §§ 12-26-6-1, 12-26-6-8(a).

[14] T.C. concedes that he was mentally ill and gravely disabled. T.C., however, argues that his commitment was inappropriate. We disagree and conclude that the trial court's finding that T.C.’s commitment was appropriate is supported by clear and convincing evidence.

[15] “ ‘The determination of whether an involuntary commitment is appropriate is fact-sensitive.’ ” J.S. v. Neuropsychiatric Hosp. of Indianapolis, 263 N.E.3d 165, 169 (Ind. Ct. App. 2025) (quoting R.P. v. Optional Behav. MHS, 26 N.E.3d 1032, 1037 (Ind. Ct. App. 2015)). T.C. argues that his commitment was inappropriate because: (1) he consistently followed medical advice and sought treatment voluntarily; (2) Dr. Ahmed conceded that ECT could be administered on an outpatient basis; and (3) no evidence indicated that hospitalization was necessary to prevent overwhelming harm. We disagree.

[16] T.C.’s involuntary commitment was appropriate due to the effects of catatonia, which impaired T.C.’s ability to communicate, execute decisive movements, and feed himself. Additionally, Dr. Ahmed feared that T.C. would not be able to navigate public transportation and that T.C. would struggle to find shelter. Although Dr. Ahmed was comfortable releasing T.C. into Brother's care, Brother declined to care for T.C. The only alternative was readmission to Center and treatment at another facility until T.C. could care for himself. Accordingly, the trial court's commitment of T.C. is supported by clear and convincing evidence.

Conclusion

[17] Clear and convincing evidence supports T.C.’s involuntary temporary commitment.

[18] Affirmed.

FOOTNOTES

1.   T.C.’s catatonia is stuporous. Stuporous catatonia is “catatonia in which the patient is subdued, mute, and negativistic, accompanied by varying combinations of staring, rigidity, and cataplexy.” “Stuporous catatonia,” Stedman’s Medical Dictionary 150600, Westlaw (database updated November 2014).

2.   Dr. Ahmed explained that this symptom occurred because T.C.’s brain did not have a fluid connection with his body movements.

3.   Dr. Ahmed described negativism as a symptom where the patient does not respond to instructions.

4.   Dr. Ahmed described ambitendency as indecisive movements.

5.   ECT is “a form of treatment of mental disorders in which convulsions are produced by the passage of an electric current through the brain.” “Electroshock therapy,” Stedman’s Medical Dictionary 913440, Westlaw (database updated November 2014) (electroconvulsive therapy and electroshock therapy are listed as synonyms under this entry).

6.   Dr. Ahmed indicated that ECT patients commonly complain of headache after treatment. Other issues with ECT include stigma and “patient concerns.” Tr. Vol. II p. 14.

7.   The trial court's order indicated that this ninety-day period lasted until May 19, 2026.

Tavitas, Chief Judge.

Bradford, J., and Felix, J., concur.