Expired involuntary commitment appeal not moot, but COA affirms commitment order

IL file photo

A man’s appeal of his expired temporary involuntary commitment order was not moot, the Court of Appeals of Indiana ruled Thursday. However, the COA also affirmed a trial’s court judgment that granted a petition for the man’s commitment, agreeing that he was a danger to himself and gravely disabled.

According to court records, in 2022, C.P. was 21 years old and owned his own construction business. Around late September or early October of that year, C.P. seemed to be “doing fine,” according to his father.

However, over the ensuing four to six weeks, C.P.’s father noticed a major shift in C.P.’s behavior, and he suddenly seemed “very delusional.”

C.P. would say that “God [wa]s speaking to him,” and he would call various people, including doctors, “the devil.” Also, he made “unusually large purchases,” including “a shotgun, a rifle, … two handguns, … two knives,” and “about $10,000 worth of tools.”

Sometime after making those purchases, C.P. had an “out-of-body experience” during which “God … told him to go to Florida to help the residents” there following a hurricane. C.P. then drove a truck with a trailer, his tools and one of his firearms to Sarasota.

But C.P. then left his truck and the other items in Sarasota and eventually ended up in Orlando. He called his parents from a hotel, and they flew to Orlando to meet him.

C.P. was “trying to come back” to Indiana, but he was unable to use his credit cards and could not pay for a hotel room or an Uber driver who had brought him to the hotel. His parents helped him out with those costs and then flew him back to Indiana.

In early November, C.P. drove to his old high school several days in a row during the high school’s basketball practices. According to C.P., he went to the practices to “teach these kids because I am financially free.”

On the third or fourth day in a row, he took a firearm and ammunition with him, which he placed in the front seat of his car. That evening, C.P., with the assistance of his former high school basketball coach, checked himself into the St. Vincent Stress Center in Indianapolis.

C.P. was examined by Dr. Carl Ratliff, who observed that C.P. had “rapid, illogical statements and thoughts” and exhibited “grandiose delusions” and “religious preoccupations.” He diagnosed C.P. with bipolar I disorder, most recent episode manic.

The doctor concluded that C.P.’s treatment plan would be a medicinal regimen. However, C.P. refused to take his prescription medication, stating that he did not need it.

The center then filed a petition for C.P.’s involuntary temporary commitment. At an ensuing factfinding hearing, Ratliff and C.P.’s father both testified in favor of his commitment.

The trial court likewise found that C.P. was a danger to himself and gravely disabled. The court then granted the center’s petition for his involuntary temporary commitment.

C.P. appealed but the appellate court affirmed, finding the St. Vincent Stress Center presented sufficient evidence to support the commitment order.

The first issue on appeal was whether C.P.’s appeal was moot given that on Feb. 14, 2023, six days before his initial brief in the Court of Appeals was due, his 90-day term of commitment expired.

According to Judge Paul Mathias, the Indiana Supreme Court “left open the possibility that respondents in [temporary-commitment appeals] could seek relief” from allegedly invalid orders due to any such consequences, citing E.F. v. St. Vincent Hosp. & Health Care Ctr., Inc., 188 N.E.3d 464 (Ind. 2022).

“Here, C.P. properly raises for our review the question left open by our Supreme Court. And, on this record, we agree with C.P. that the collateral consequences that accompany his involuntary civil commitment order make his appeal from that order not moot even though the term of his commitment has expired,” Mathias wrote.

However, on the merits, the appellate court found the center presented sufficient evidence to show that C.P. was gravely disabled and a danger to himself.

Mathias wrote that C.P. suffered a rapid deterioration of his sense of reality, going from “fine” to “very delusional” in a matter of four to six weeks and experiencing very rapid mood swings, from irritable and aggressive to pleasant and cooperative.

Further, Ratliff opined that C.P.’s mental illness was such that C.P. “will have a difficult time functioning” independently as an outpatient, and the doctor had “concerns about [C.P.’s] … safety” because his symptoms “will predispose him to poor decision-making.”

“We hold that a reasonable fact-finder could conclude from those facts that C.P. was gravely disabled,” Mathias wrote.

Judges Nancy Vaidik and Rudolph Pyle concurred in In the Matter of the Civil Commitment of: C.P. v. St. Vincent Hospital and Health Care Center, Inc. d.b.a. St. Vincent Stress Center, 22A-MH-2960.