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The Court of Appeals has dismissed as moot the appeal of a woman’s involuntary commitment, determining the collateral consequences doctrine does not apply in her case.
At the time of her most recent commitment hearing, appellant-respondent J.F. was 39 years old. She struggled with substance abuse and was diagnosed with “psychotic disorder unspecified.”
Early in January, J.F.’s parents began to recognize a “significant” change in her behavior, most notably an increase in severe paranoia and delusions.
At that time, J.F.’s paranoia focused on her employment. She believed her co-workers were part of a “crime family” who “targeted” and “harassed” her.
Eventually, J.F. lost her job.
On Jan. 24, J.F.’s father returned to his home and found J.F. in his closet. When confronted, J.F. pleaded, “Please don’t kill me. Please don’t kill me.”
The next day, J.F. “barricaded at the top of the stairs” at her parents’ house. When her parents went upstairs to investigate, they found J.F. and her two young children locked in the bathroom.
When recounting the incident, J.F. said she believed someone was threatening her kids because she “was getting weird messages … through Facebook” that would appear and then be deleted as if “someone was on that phone with [her].”
J.F. was subsequently hospitalized.
Following her release, J.F. lived in her car and a motel. Within a short time, she was admitted to the St. Vincent Stress Center.
In February, the Stress Center unsuccessfully sought to involuntarily commit J.F. But she was recommitted the following month after another incident at her parents’ home.
The Stress Center again sought involuntary commitment, with an attending psychiatrist opining that J.F. was gravely disabled.
This time, the Marion Superior Court determined J.F. suffered from a mental illness and was gravely disabled, although it did not find that she was dangerous.
J.F. appealed her temporary involuntary commitment, arguing it was not supported by sufficient evidence.
But the Court of Appeals dismissed her appeal, determining it was moot and does not fall within an exception to the mootness doctrine.
Judge Dana Kenworthy wrote the opinion for the appellate court.
Kenworthy noted the appellate court recently considered the merits of appeals from expired temporary commitment orders without invoking the public interest exception to the mootness doctrine in Civ. Commitment of C.P. v. St. Vincent Hosp. & Health Care Ctr., Inc., and Civ. Commitment of M.T. v. Cmty. Health Network.
“As explained in C.P., Indiana appellate courts have applied the ‘collateral consequences’ doctrine to hold that appeals are not moot where review of appeals on their merits may still provide meaningful relief,” Kenworthy wrote. But here, “J.F.’s appeal does not address a novel issue, present a close call, or provide an opportunity to develop case law on a complicated topic.
“… Accordingly, we do not believe it is appropriate to invoke the public interest exception to reach the merits of J.F.’s appeal,” the judge wrote.
Further, “Although J.F. raised a collateral consequence — an addition to her medical history which would make future involuntary commitment proceedings against her more likely to succeed — she has not sufficiently shown a particularized harmful consequence would befall her if this Court declined to reach the merits of her appeal,” Kenworthy concluded. “Thus, we will not apply the collateral consequences doctrine.”
Judges L. Mark Bailey and Elizabeth Tavitas concurred in In the Matter of the Civil Commitment of: J.F. v. St. Vincent Hospital and Health Care Center, Inc. d/b/a St. Vincent Stress Center, 23A-MH-752.
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