The Indiana Court of Appeals (the “Court”) in In re Commitment of G.J. emphasized the significance of hospital recidivism and catatonia as evidence and upheld the trial court’s Order for Temporary Commitment. No. 24A-MH-3101, 2025 WL 2438216 (Ind. Ct. App. 2025).

Background

G.J., diagnosed with schizophrenia, presented with symptoms of catatonia and periods of psychosis. She initially stated she would continue taking her medication outside the hospital, but also expressed she did not believe she needed medication. Although G.J. testified she could provide for her own needs, in the hospital, she required strong prompting to eat, drink, bathe and take her medications. Over the course of four years, G.J. had been hospitalized 10 times.

Analysis of Grave Disability

G.J. argued that the only evidence supporting her commitment was her refusal of medication and lack of insight into her illness, which alone cannot establish grave disability. The Court disagreed, finding her medication refusal not only triggered aggression and paranoia but also led to catatonic episodes, leaving her unable to function independently. Viewed in the light most favorable to the trial court, the evidence showed G.J. had been hospitalized 10 times over the preceding four years, repeatedly refused medication when not committed and faced a risk of developing catatonia and increasing resistance to effective treatment for her psychosis. The Court noted catatonia had caused her harm in the past, and each episode becomes increasingly difficult to treat. This pattern of repeated hospitalization and refusing medication, combined with the risk of catatonia, clearly and convincingly supported the trial court’s finding that G.J. was gravely disabled.

Practical Takeaways

  • Patterns of Medication Resistance that Lead to Harm: While past noncompliance with medication alone may not establish grave disability, a demonstrated pattern of refusing medication resulting in personal harm can support a finding of grave disability.
  • Frequency of Hospitalization as Evidence: Repeated hospitalizations over a short period may indicate an inability to function independently and support a finding of grave disability.

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