Trial court must review treatment plan for mental patient, COA rules

A man who challenged his ongoing commitment to a mental health facility got a partial victory in that the trial court has been ordered to review his medication to determine if it is substantially benefiting him.

Forty-three-year-old W.S. suffers from paranoid schizophrenia and has been committed to Midtown Community Mental Health since March 2009. He lives independently but must attend scheduled appointments at Midtown and receive monthly injections of Haldol Decanoate.

In February 2014, W.S. petitioned for a review of his regular commitment, arguing he does not have a mental illness and does not need the medication.

The Marion Superior Court concluded W.S. suffers from mental illness and is gravely disabled. It ordered his recommitment and medication to continue.

The Indiana Court of Appeals affirmed the trial court’s finding that W.S. is mentally ill and gravely disabled but it remanded for further hearing on the issue of the court-ordered injections.

W.S. challenged the commitment order’s requirement that he continue to take all medications as prescribed. He asserted there was insufficient testimony presented to establish that the continuation of Haldol Decanoate injections would substantially benefit him and that those benefits outweighed any risk of harm.

The Court of Appeals noted Midtown failed to respond to this issue. It also pointed to In re Mental Commitment of M.P, 510 N.E.2d 645, 646 (Ind. 1987) which held that forcible medication interferes with a mental patient’s interest in remaining free of unwarranted intrusions.  

“Indeed, there was evidence presented that the probable benefits from the monthly injections outweigh the risk of harm and personal concerns of W.S. as the record indicates that, despite the pain and violation W.S. feels from the injections, he would deteriorate into a chronic psychotic state without them,” Judge Terry Crone wrote in In the Matter of the Civil Commitment of W.S. v. Eskenazi Health, Midtown Community Mental Health, 49A02-1404-MH-274. “But, there does appear to be a lack of specific evidence presented that the injections provided a substantial benefit in treating W.S.’s schizophrenia, and not just controlling his behavior.”