Commitment of G W

CourtIndiana Court of Appeals
DecidedSeptember 20, 2024
Docket23A-MH-02452
StatusPublished

This text of Commitment of G W (Commitment of G W) is published on Counsel Stack Legal Research, covering Indiana Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commitment of G W, (Ind. Ct. App. 2024).

Opinion

FILED Sep 20 2024, 8:49 am

CLERK Indiana Supreme Court Court of Appeals and Tax Court

IN THE

Court of Appeals of Indiana Commitment of G.W., Appellant-Respondent,

v.

Madison State Hospital, Appellee-Petitioner.

September 20, 2024

Court of Appeals Case No. 23A-MH-2452

Appeal from the Marion Superior Court

The Honorable David Certo, Judge

Trial Court Cause No. 49D08-2303-MH-12196

Court of Appeals of Indiana | Opinion 23A-MH-2452 | September 20, 2024 Page 1 of 16 Opinion by Senior Judge Robb Judges Bailey and Weissmann concur.

Robb, Senior Judge.

Statement of the Case [1] G.W. is a deaf person who has been diagnosed with several medical conditions,

including mental illness. He appeals the trial court’s order of regular

commitment, directing that he remain at the Madison State Hospital

(“Hospital”) for at least ninety days. It appears that G.W. is still at the 1 Hospital, and in any event the Hospital does not claim this appeal is moot.

[2] G.W. challenges the trial court’s decision to hold an evidentiary hearing via

video conference. He also challenges the appropriateness of his placement at

the Hospital. We conclude the trial court did not commit reversible error in

holding the hearing via video conference, but the Hospital failed to show its

facility is the appropriate place for G.W. We affirm in part, reverse in part, and

remand with instructions.

1 On June 4, 2024, G.W. filed a status report to inform the Court he is still hospitalized. The Hospital has moved to strike the status report and other items from the record. We grant the Hospital’s motion by separate order.

Court of Appeals of Indiana | Opinion 23A-MH-2452 | September 20, 2024 Page 2 of 16 Facts and Procedural History [3] G.W. was fifty-eight years old during the time relevant to this appeal. The

record tells us little about G.W.’s medical history or diagnoses before his

current involuntary commitment, except that he was taking medication for

mental illness. He had lived in a group home for deaf persons and worked in a

restaurant. The group home closed due to lack of funding. G.W. moved to an

apartment complex near other deaf people, but he could not afford to continue

living there. He decompensated due to not taking his medication and losing

access to his deaf community, and he ended up in a homeless shelter.

[4] This case began on March 24, 2023, when the Community Health Network

(“the Network”) filed a report on emergency detention regarding G.W. On

March 27, the trial court committed G.W. to the Network’s care for up to

ninety days because he was “mentally ill and gravely disabled.” Appellant’s

App. Vol. II, p. 9.

[5] On May 11, 2023, G.W. was transferred to the Hospital’s facility in Madison,

Indiana under circumstances not explained in the record. On June 6, the

Hospital filed a “Report Requesting Extension of Temporary Commitment and

Physician’s Statement.” Id. at 10. The trial court held a hearing by video

conference and concluded G.W. “is suffering from Psychosis, unspecified,

Mood Disorder, unspecified, PTSD, Generalized Anxiety Disorder, Personality

Disorder, unspecified[.]” Id. at 48. The court further determined G.W. was

Court of Appeals of Indiana | Opinion 23A-MH-2452 | September 20, 2024 Page 3 of 16 gravely disabled. As a result, the court ordered G.W. to remain at the Hospital

for no more than ninety days.

[6] On August 30, 2023, the Hospital filed a Report Requesting Regular

Commitment, alleging G.W. needed inpatient treatment for longer than ninety

days. The Hospital provided a statement from G.W.’s psychiatrist, Dr. Jill

Zinner. Dr. Zinner discussed G.W.’s condition and further stated, “A

courtroom hearing will have a harmful effect on the Respondent’s health or

well-being. It is recommended that the hearing be held at the [Hospital] or

other suitable place[.]” Id. at 19.

[7] On September 11, 2023, the trial court issued an order scheduling an

evidentiary hearing for September 18, to be held “over video.” Id. at 20. The

order cited Dr. Zinner’s statement.

[8] On September 14, the Hospital moved to appear via telephonic or video

technology. At a minimum, the Hospital asked that its witnesses and counsel

be allowed to appear remotely rather than being required to travel to Marion

County. On the same day, G.W. filed an objection to holding the hearing via

video conference and asked the court to arrange for him to be transported to

Marion County for an in-person hearing. He argued that as a deaf person, an

in-person hearing would better meet his needs and satisfy the requirements of

“due process[.]” Id. at 28.

[9] The evidentiary hearing was held as scheduled via video conference on

September 18. A team of interpreters was present. Two of them were “ASL,”

Court of Appeals of Indiana | Opinion 23A-MH-2452 | September 20, 2024 Page 4 of 16 or American Sign Language, interpreters, and two others were “CVI” (perhaps

a mistype of CDI, meaning Certified Deaf Interpreter). Tr. Vol. 2, p. 4. One of

the interpreters explained it was her first time working in this setting. Another

interpreter expressed concerns that G.W. may not have visual access to her and

may not understand the proceedings.

[10] The trial court arranged to place the interpreters, G.W., and his counsel in a

private virtual room so they could discuss how to proceed. Before the private

conference began, the court advised G.W. that if he intended to “pursue the

objection” to a virtual hearing, the case “should” be transferred to Jefferson

County. Id. at 5.

[11] After the conference, the interpreters explained to the court they had worked

out a process to interpret for G.W. Next, G.W., by counsel, stated he did not

want to transfer the case to Jefferson County and establish a new attorney-client

relationship with only four days left in his term of commitment. He preferred

“to go forward today.” Id. at 8. But G.W. noted it would be “cumbersome and

fatiguing” for the interpreters and G.W. to participate in a two-to-three-hour

hearing. Id. at 9. He asked the court to break the hearing down into shorter

sessions over the next three days. The court denied G.W.’s proposal as

“unworkable” and proceeded. Id. We address the evidence presented at the

hearing in the discussion section of this opinion. During the hearing, a member

of the interpreter team had to leave and was replaced by another interpreter.

Court of Appeals of Indiana | Opinion 23A-MH-2452 | September 20, 2024 Page 5 of 16 [12] After the hearing, the trial court issued an order stating G.W. is mentally ill and

gravely disabled. In particular, the court noted G.W.’s “judgment and

reasoning” are suspect, as shown by his paranoid belief that Hospital staff “may

attack him.” Appellant’s App. Vol. II, p. 15. The court directed that he remain 2 at the Hospital for at least ninety days. This appeal followed.

Discussion and Decision I. Holding Evidentiary Hearing by Video Conference [13] G.W. argues the trial court violated Indiana’s administrative rules, as well as

his constitutional rights to due process and due course of law, by holding the

evidentiary hearing remotely rather than in person. He first cites Indiana

Administrative Rule 14(C) (effective January 1, 2023):

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Commitment of G W, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commitment-of-g-w-indctapp-2024.