COA Reverses Involuntarily Mental Health Commitment


Olivia Covington for

A woman involuntarily committed to the Evansville State Hospital for mental health treatment must be released after the Indiana Court of Appeals determined Friday there was insufficient evidence to support her commitment.

As a result of her diagnosis with schizoaffective disorder and post-traumatic stress disorder, P.B. suffered from paranoia and delusions and believed her mother was conspiring to harm her. She was also “poorly compliant” with outpatient treatment because she believed her medication was poisonous.

P.B. was admitted to the Evansville State Hospital on Feb. 13, and one day later the St. Joseph Superior Court entered an order to continue her regular commitment without a hearing. After P.B. filed for dismissal of her commitment, the trial court held a hearing, where Dr. Boris Vatel testified in favor of continuing the commitment because she was gravely disabled.

The trial court ultimately continued P.B.’s involuntary commitment, but the Indiana Court of Appeals reversed that decision on Friday. Judge Michael Barnes, writing for the unanimous panel, pointed T.K. v. Department of Veteran Affairs, 27 N.E.3d 271, 273 (Ind. 2015), which disapproved of the Court of Appeals using a standard of review that affirmed involuntary commitments “merely if a reasonable person could have drawn the conclusion that commitment was necessary, even if other reasonable conclusions were possible.”

Although P.B. had paranoid delusions and often had confrontations with her neighbors, there was no evidence her delusions caused her to destroy property or harm herself or other people, Barnes said. Additionally, there was no evidence she was unable to provide food, clothing and shelter for herself, he said.

 “Essentially, Dr. Vatel’s recommendation in favor of P.B.’s continued involuntary commitment was based on her unpleasantness and inability to get along with other people, her paranoid delusions, and her failure to fully cooperate with treatment,” the judge wrote. “None of this is untrue, and there is no doubt that P.B. suffers from severe mental illness. However, the statutory definition of ‘gravely disabled’ is very specific, and it has not been met here.”

Thus, the appellate panel concluded P.B.’s regular involuntary commitment deprived her liberty without sufficient evidence.

The case is In the Matter of the Commitment of P.B. v. Evansville State Hospital, 71A03-1706-MH-1362.