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Published by the Indiana Office of Court Services

In re Commitment of M.C., No. 25S-MH-187, __ N.E.3d __ (Ind., July 18, 2025)

July 21, 2025 Filed Under: Civil Tagged With: Per Curiam, Supreme

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Per Curiam

In J.F. v. St. Vincent Hosp. and Health Care Ctr., Inc., 256 N.E.3d 1260 (Ind. 2025), we held that the appeal of a temporary commitment order is not moot—even if the commitment has expired—unless the appellee shows that there are no collateral consequences from the commitment. Before we handed down J.F., the Court of Appeals dismissed M.C.’s appeal as moot, finding the commitment order had expired and appellant M.C. failed to identify any particularized collateral consequences stemming from his commitment.

Because the Court of Appeals dismissal is at odds with J.F., we grant transfer to vacate the decision. We also find that sufficient evidence supports M.C.’s commitment and thus affirm the trial court’s temporary commitment order.

….

Though decided without the benefit of J.F., the Court of Appeals decision conflicts with J.F. in two ways: first, by finding the appeal was moot, and second, by improperly placing the burden on M.C. to show collateral consequences. We thus grant transfer to vacate the Court of Appeals decision. Ind. Appellate Rule 58(A).

….

The probative evidence supporting the commitment order shows that M.C. was fixated on going to Washington, D.C. He refused treatment, believing his delusions were real. We acknowledge there is some evidence M.C. planned to call his family for money or shelter upon discharge. But the trial court apparently gave more weight and credibility to Dr. Ahmed’s concern that M.C.’s fixation on Washington, D.C., and lack of independent financial resources would impair his ability to provide for himself. Because our standard of review restrains us from reweighing evidence, we find that the trial court could reasonably conclude that clear and convincing evidence supported M.C.’s temporary commitment.

Conclusion

We grant transfer to resolve the conflict between J.F. and the Court of Appeals decision in this case. We find sufficient evidence supports M.C.’s commitment and affirm the trial court’s commitment order.

Rush, C.J., and Massa, Goff, and Molter, JJ., concur. S

laughter, J., dissents, believing that transfer should be denied

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