J.M. v. Ne. Ctr., Inc. (In re Commitment of J.M.)
Citation | 62 N.E.3d 1208 |
Decision Date | 27 October 2016 |
Docket Number | No. 76A05–1509–MH–1477.,76A05–1509–MH–1477. |
Parties | In the Matter of the COMMITMENT OF J.M., J.M., Appellant–Respondent, v. Northeastern Center, Inc., Appellee–Petitioner. |
Court | Court of Appeals of Indiana |
Robert J. Hardy, Hardy Law Office, Auburn, IN, Attorney for Appellant.
Eugene C. Bosworth, Angola, IN, Attorney for Appellee.
, Judge.
[1] J.M. appeals her involuntary mental health commitment. Though the issue raised on appeal is moot, we address J.M.'s argument because it is a matter of great public importance. On the merits of her argument, we hold that there was sufficient evidence to support her temporary commitment. As such, we affirm.
[2] On August 10, 2015, Northeastern Center, Inc. (“Northeastern”) filed a petition for the involuntary commitment of J.M. due to mental health concerns. The court held a fact-finding hearing on August 13 and August 20.1 At that hearing, Dr. Lynnea T. Carder testified as follows:
....
* * *
Since admission, we've observed her getting very religiously preoccupied, ... explosive. We've actually had to restrain her and seclude her at various times throughout her time here. She's somewhat paranoid. She doesn't trust me. She doesn't trust my qualifications to treat her. Difficult to engage and difficult to have her follow rules and comply with treatment....
* * *
In April of this year, ... a family member called our hotline voicing concern because she had been living without heat and electricity and wasn't caring for herself. And I think shortly thereafter[ ] they had her move in with family. And now she is, essentially, disowning her family—wanting nothing to do with them because she believes they are manipulating and are the ones that took her here.... [S]he has no other means of support—nowhere to go. So she actually was in danger and not having shelter and caring for herself.
[3] Following the conclusion of the fact-finding hearing, the trial court found that J.M. suffered from a mental illness, was dangerous, and was gravely disabled. Accordingly, the court ordered J.M. to be committed for a period not to exceed ninety days at Northeastern or another appropriate facility. This appeal ensued.
[4] J.M. appeals her involuntary commitment at Northeastern. However, we first acknowledge Northeastern's response that, as J.M.'s ninety-day commitment has expired, her appeal is moot. Northeastern is correct. “When a court is unable to render effective relief to a party, the case is deemed moot and usually dismissed.” In re J.B., 766 N.E.2d 795, 798 (Ind.Ct.App.2002)
(citing In re Lawrance, 579 N.E.2d 32, 37 (Ind.1991) ).
[5] However:
“Although moot cases are usually dismissed, Indiana courts have long recognized that a case may be decided on its merits under an exception to the general rule when the case involves questions of ‘great public interest.’ ” [In re Lawrance, 579 N.E.2d at 37
.] Typically, cases falling in the “great public interest” exception contain issues likely to recur. Id.; see Ind. High Sch. Athletic Ass'n, Inc. v. Durham, 748 N.E.2d 404, 412 (Ind.Ct.App.2001)
(“Although Indiana does not require that the issue be capable of repetition, cases falling into the public interest exception usually involve issues that are likely to recur.”).
[6] On the merits of her appeal, J.M. asserts that Northeastern failed to present sufficient evidence to support her involuntary commitment. As we have explained:
When reviewing a challenge to the sufficiency of the evidence, we look to the evidence most favorable to the trial court's decision and all reasonable inferences drawn therefrom. In re Commitment of G.M., 743 N.E.2d 1148, 1150–51 (Ind.Ct.App.2001)
. If the trial court's commitment order represents a conclusion that a reasonable person could have drawn, the order must be affirmed, even if other reasonable conclusions are possible. Id. at 1151. In an involuntary commitment case, the petitioner must prove by clear and convincing evidence: “(1) the individual is mentally ill and either dangerous or gravely disabled; and (2) detention or commitment of that individual is appropriate.” Ind.Code § 12–26–2–5(e).
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