In re L.A.

Summary

The Vermont Supreme Court held that a family court evaluating a petition for involuntary psychiatric medication must determine whether the patient is able to make a medication decision and appreciate its consequences, rather than infer incompetence from refusal of beneficial medication or mental illness alone. The court reversed and remanded for a new competency hearing because the family court made insufficient findings regarding the patient's decision-making capacity. The court declined to reach the merits of the patient's Religious Land Use and Institutionalized Persons Act claim, but permitted him to renew it on remand with adequate notice.

Holdings

1. Under 18 V.S.A. § 7625(c), competency to refuse medication depends on whether the patient is able to make a decision about medication and appreciate the consequences of that decision; it does not depend solely on mental illness, disagreement with a psychiatrist, refusal of medication, or the medication's potential benefits.
2. The family court's findings were inadequate to support a determination that L.A. was incompetent to refuse medication because the court did not specifically examine his ability to make a medication decision or appreciate its consequences.
3. The standards governing involuntary commitment cannot alone establish incompetence to refuse medication; involuntary medication requires the separate, more specific decision-making inquiry required by § 7625(c).
4. L.A.'s RLUIPA claim was not timely raised because it was first mentioned during closing argument, depriving the Commissioner of notice and an opportunity to develop evidence concerning the claim's elements; however, L.A. could raise the claim again on remand with adequate notice.

Questions Presented

1. Whether the family court applied the correct statutory standard for determining whether L.A. was competent to refuse involuntary psychiatric medication.
2. Whether the family court's findings regarding L.A.'s mental illness, delusions, refusal of beneficial medication, and religious objections supported a finding of incompetence.
3. Whether L.A.'s RLUIPA claim concerning religious exercise and involuntary medication could be decided when it was first raised during closing argument.

Disposition

reversed_and_remanded