The Indiana Court of Appeals (the “Court”) affirmed the trial court’s regular commitment of a patient whose mental illness stemmed from a traumatic brain injury (“TBI”). In its reasoning, the Court connected the past event to the patient’s current aggressiveness, emotional outbursts, inability to provide for basic needs and lack of insight into illness as support for its decision. B.D. v. Richmond State Hosp., 270 N.E.3d 515 (Ind. Ct. App. 2025) (unpublished table decision).

Background

B.D. was admitted to Richmond State Hospital in July 2024. At age nine, B.D. suffered a TBI. The TBI left her comatose and resulted in significant frontal-temporal lobe damage. Upon admission to the hospital, B.D., who has a history of mental illness, was diagnosed with orbitofrontal neurocognitive disorder and intermittent explosive disorder, secondary to head trauma.

During her admission, B.D.’s treating mental health providers observed many emotional outbursts, including severe agitation that required her to be accompanied by additional staff for safety measures. B.D.’s psychiatrist explained at the hearing how an individual with significant frontal lobe damage can experience extreme mood swings, verbal and physical aggression, lack of empathy and lack of understanding of the impacts of their behavior. B.D.’s outbursts, issues regulating bodily functions like urination and defecation and need for assistance with bathing, using the bathroom and getting dressed demonstrated these challenges. The psychiatrist explained that B.D. lacked insight into her condition, took a lot of convincing from staff to take her medication and had developed an unspecified personality and behavioral disorder. He did not believe that B.D. would be able to take care of her daily needs if released from the hospital.

The trial court held B.D. suffered from a mental illness, was a danger to herself and was gravely disabled. B.D. appealed the finding of dangerousness and grave disability.

Dangerousness and Grave Disability Analysis

B.D. argued that prior to hospitalization, she was able to do her own shopping, pick up medications, administer those medications and, at the time of the hearing, bathe herself. Thus, she argued she could provide for her basic needs and function independently, and the trial court’s findings of dangerousness and grave disability were not supported by sufficient evidence.

The Court disagreed, reasoning that B.D. had no insight into her illness and could not manage the daily needs required by her illness. Furthermore, B.D.’s aggressiveness posed a danger to others and, because of her feelings of hopelessness, possibly herself. The Court noted the evidence that she also had a supervision restriction due to her aggressiveness and was occasionally placed on chair restrictions during her outbursts also supported a finding that she was dangerous. She often needed convincing to take her medication, and her psychiatrist believed she could not function outside of a structured hospital environment.

For these reasons, the Court affirmed the trial court’s findings.

Practical Takeaways

  • Mental Illness Can Result from Many Experiences and Lead to Involuntary Commitment: A TBI can be the initial event that leads to other mental health conditions and can provide helpful background information for a court that is ruling on an involuntary commitment.
  • Past Actions Do Not Outweigh Present Evidence: Even when patients demonstrate they could previously perform actions that do not meet the threshold for temporary commitment, courts look to the present evidence in front of them and rely on the provider’s testimony to understand the extent of an illness.

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