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

Summary

The Indiana Supreme Court granted expedited transfer in an involuntary civil commitment appeal involving A.D. and Community Fairbanks Behavioral Health. The court disapproved language suggesting that a commitment order must be affirmed whenever a reasonable person could have reached the trial court’s conclusion, but summarily affirmed the Court of Appeals’ decision because sufficient evidence supported the commitment.

Holdings

1. Appellate courts must review the probative evidence and reasonable supporting inferences without weighing evidence or assessing witness credibility, and must affirm if a reasonable factfinder could find the necessary commitment elements proven by clear and convincing evidence. The alternative formulation that an order must be affirmed whenever it represents a conclusion a reasonable person could have drawn is improper because it dilutes the clear-and-convincing burden.
2. Sufficient evidence supported A.D.'s temporary civil commitment despite the Court of Appeals' misstated standard of review.

Questions Presented

1. What is the proper appellate standard of review for an involuntary civil commitment?
2. Whether Community Fairbanks Behavioral Health proved by clear and convincing evidence that A.D. had a mental illness as required by Indiana Code section 12-26-2-5(e).

Disposition

other