Commitment of K K

CourtIndiana Court of Appeals
DecidedAugust 1, 2023
Docket23A-MH-00114
StatusPublished

This text of Commitment of K K (Commitment of K K) 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 K K, (Ind. Ct. App. 2023).

Opinion

FILED Aug 01 2023, 8:50 am

CLERK Indiana Supreme Court Court of Appeals and Tax Court

ATTORNEY FOR APPELLANT ATTORNEYS FOR APPELLEE Valerie K. Boots Jenny B. Buchheit Marion County Public Defender Agency Sean T. Dewey Indianapolis, Indiana Alexandria H. Pittman Ice Miller LLP Indianapolis, Indiana

IN THE COURT OF APPEALS OF INDIANA

In the matter of the Civil August 1, 2023 Commitment of: Court of Appeals Case No. 23A-MH-114 K.K., Appeal from the Appellant-Respondent, Marion Superior Court v. The Honorable Steven Eichholtz, Judge Community Health Network, The Honorable Inc., Melanie Kendrick, Magistrate

Appellee-Petitioner Trial Court Cause No. 49D08-2212-MH-43185

Opinion by Judge Vaidik Judges Mathias and Pyle concur.

Court of Appeals of Indiana | Opinion 23A-MH-114 | August 1, 2023 Page 1 of 9 Vaidik, Judge.

Case Summary [1] K.K. appeals the trial court’s order involuntarily committing her to Community

Health Network, Inc. (“the Hospital”). In addition to challenging the

sufficiency of the evidence, K.K. argues the court erred in allowing her doctor

to testify as an expert under Indiana Evidence Rule 702. Her doctor, although

still a resident, had graduated medical school and had been treating patients for

several months. The trial court determined this was sufficient knowledge and

experience to qualify as an expert, and we cannot say this was an error. And

because we find there is sufficient evidence to support the involuntary

commitment, we affirm.

Facts and Procedural History [2] In the early morning hours of December 13, 2022, residents of a home in

Marion County called police and reported K.K., whom they did not know, had

been standing on their front porch for hours, clothed only in pajamas. Police

believed K.K. was displaying “erratic behavior” and took her to the Hospital,

where she was admitted. Tr. Vol. II p. 11.

[3] Over the next few days, Dr. Beatrice Thunga, a psychiatry resident at the

Hospital, examined K.K. and found her to have a “disorganized thought

process” and “disorganized behavior.” Id. at 12. Specifically, K.K. was “barely

talking” and, when she did talk, was “incoherent.” Id. at 13. When asked Court of Appeals of Indiana | Opinion 23A-MH-114 | August 1, 2023 Page 2 of 9 questions, she would not reply and instead produced items, such as a crayon or

a piece of paper, but could not explain their significance. Furthermore, she was

“unable to express emotions” and did not understand that she had a mental

illness or needed to take medication. Id. Based on her behavior and prior

medical history, including an involuntary commitment earlier that year, doctors

at the Hospital diagnosed K.K. with schizoaffective disorder, bipolar type. On

December 15, a report was filed with the court requesting temporary

involuntary commitment (up to ninety days).

[4] An evidentiary hearing was held on December 20. Dr. Thunga testified that she

had recently graduated medical school in May 2022, held a temporary medical

license, and was six months into her residency at the Hospital. For four of those

months, she had been working in psychiatry, which she identified as the

“particular focus of [her] training.” Id. at 7-8. She primarily worked with adult

patients “with various mental disorders of mood, substance use and psychosis.”

Id. at 8. Over K.K.’s objection, the trial court found Dr. Thunga met the

qualifications as an expert in psychiatry.

[5] Dr. Thunga testified she had examined K.K. nine times since her admission

and confirmed that K.K. had been diagnosed with schizoaffective disorder,

bipolar type. Dr. Thunga stated K.K. suffered from “poverty of speech,”

meaning that K.K. was “barely talking” and often “incoherent” when she did

speak. Id. at 13. Dr. Thunga expressed that K.K. showed “declining cognition”

and was unable to coherently answer questions about her medical care,

housing, or basic needs. Id. Dr. Thunga also noted that it appeared K.K. was

Court of Appeals of Indiana | Opinion 23A-MH-114 | August 1, 2023 Page 3 of 9 not showering, had been wearing the same clothes for almost a week, and was

not eating. A friend of K.K.’s testified at the hearing and stated he could give

her a temporary place to stay should she be released but could not offer any

permanent housing and was unwilling to be responsible for her taking

prescribed medication or attending medical appointments.

[6] After the hearing, the trial court entered an order of temporary commitment not

to exceed ninety days.

[7] K.K. now appeals.1

Discussion and Decision I. Expert Testimony [8] K.K. first argues the trial court erred in allowing Dr. Thunga to testify as an

expert witness under Indiana Evidence Rule 702, which provides,

(a) A witness who is qualified as an expert by knowledge, skill, experience, training, or education may testify in the form of an opinion or otherwise if the expert’s scientific, technical, or other specialized knowledge will help the trier of fact to understand the evidence or to determine a fact in issue.

1 As K.K. acknowledges, her commitment expired on March 20, 2023. But the Hospital does not argue the appeal should be dismissed as moot. Therefore, we will address the issues raised by K.K.

Court of Appeals of Indiana | Opinion 23A-MH-114 | August 1, 2023 Page 4 of 9 (b) Expert scientific testimony is admissible only if the court is satisfied that the expert testimony rests upon reliable scientific principles.

“Two requirements must be met for a witness to qualify as an expert.” Totton v.

Bukofchan, 80 N.E.3d 891, 894 (Ind. Ct. App. 2017). “First, the subject matter

must be distinctly related to some scientific field, business, or profession beyond

the knowledge of the average layperson; and second, the witness must be

shown to have sufficient skill, knowledge, or experience in that area so that the

opinion will aid the trier of fact.” Id.

[9] The trial court is considered the gatekeeper for the admissibility of expert

opinion evidence under Rule 702. McDaniel v. Robertson, 83 N.E.3d 765, 773

(Ind. Ct. App. 2017). A trial court’s determination regarding the admissibility of

expert testimony under Rule 702 is a matter within its broad discretion and will

be reversed only for abuse of that discretion. Id. at 772. We presume that the

trial court’s decision is correct, and the burden is on the party challenging the

decision to persuade us that the trial court has abused its discretion. Id. at 773.

[10] K.K. argues the Hospital did not show Dr. Thunga had sufficient experience to

qualify as an expert. Dr. Thunga completed four years of medical school and

held a temporary medical license. She had been through six months of

residency, four of which focused on psychiatry. She identified psychiatry as the

focus of her training and had experience treating adults with “various mental

disorders of mood, substance use and psychosis.” And she was K.K.’s treating

physician, examining her nine times while she was there. Given this evidence,

Court of Appeals of Indiana | Opinion 23A-MH-114 | August 1, 2023 Page 5 of 9 and the deference given to trial courts in these circumstances, we cannot say the

court erred in determining Dr.

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