COA upholds involuntary mental health commitment

A man who challenged his involuntary mental health commitment after he had already been released failed to convince the Court of Appeals of Indiana that he shouldn’t have been held against his will.

C.M. was released from jail in January and voluntarily went to the Richard L. Roudebush Veterans Affairs Medical Center’s emergency department in Indianapolis. Though C.M. went to Roudebush to receive assistance with housing, he eventually began talking to himself and yelling “to the Holy Spirit about a variety of things.”

C.M., who has a history of mental illness, was described as being “manic with racing thoughts, pressured, delusional[,]” and “experiencing symptoms of mania that have compromised his housing […] resulting in concerning behavior.”

That same day, Roudebush filed an application for emergency detention of a mentally ill person, stating that if C.M. was not restrained immediately he “[would] be unable to care for [his] basic needs.”

At some point during his stay at Roudebush, C.M. made threatening comments to a doctor, telling her that he had “a license to kill” and that he was going to “unleash an arsenal of armory upon you[.]” C.M. was also observed rummaging through “biohazard bags full of used personal protective equipment,” then rewearing those materials himself and “building a shrine from it […] using a variety of pieces to decorate his room.”

Additionally, court records state C.M. was verbally aggressive with staff and threw things at others, destroyed a toilet in his room by pulling up the wax seal and drank three bottles of mouth wash.

An evidentiary hearing was held and the Marion Superior Court entered an order of temporary commitment. That order was set to expire on April 13 unless C.M. was discharged prior to that date.

On appeal, C.M. argued that the evidence was insufficient to support the order and that his case should be reviewed despite mootness as it presented issues of great public interest.

While the COA concluded there was a great public interest in reviewing C.M.’s appeal, the appellate court affirmed his commitment.

“There was clear and convincing evidence to support the trial court’s findings that C.M. was a danger to himself and others and was gravely disabled,” Chief Judge Cale Bradford wrote for the COA. “Dr. Stalnaker testified that based on her review of C.M.’s medical records, he has a history of becoming homeless and incarcerated when he does not take his medications. Dr. Stalnaker testified at C.M.’s commitment hearing that she believed that he was a danger to himself and others.”

Further, the COA noted how C.M.’s history of “mania” and “delusions of grandeur” made it so that he couldn’t function independently.

The case is In re: The Civil Commitment of C.M., C.M. v. Richard L. Roudebush Veterans Affairs Medical Center, 22A-MH-218.