In the Matter of the Civil Commitment of A.D. v. Community Fairbanks Behavioral Health

Summary

The Indiana Court of Appeals affirmed an order temporarily committing A.D. involuntarily to Community Fairbanks Behavioral Health. The court held that clear and convincing evidence supported the trial court’s finding that A.D. suffered from schizoaffective disorder, bipolar type, and rejected her challenge to the sufficiency of the diagnostic evidence.

Holdings

1. Clear and convincing evidence supported the trial court's finding that A.D. suffered from schizoaffective disorder, bipolar type, and therefore satisfied the mental-illness element of the temporary commitment statute.
2. For purposes of involuntary commitment, Indiana Code section 12-7-2-130 does not require a definitive, textbook diagnosis to establish mental illness by clear and convincing evidence.

Questions Presented

1. Whether clear and convincing evidence supported the trial court's finding that A.D. suffered from a mental illness under Indiana Code section 12-7-2-130.
2. Whether the psychiatrist's inability to establish the precise duration of A.D.'s symptoms rendered his diagnosis insufficient to support temporary involuntary commitment.

Disposition

affirmed