for the Best Interest and Protection of E.V.A.

CourtCourt of Appeals of Texas
DecidedDecember 22, 2005
Docket01-05-00872-CV
StatusPublished

This text of for the Best Interest and Protection of E.V.A. (for the Best Interest and Protection of E.V.A.) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
for the Best Interest and Protection of E.V.A., (Tex. Ct. App. 2005).

Opinion

Opinion issued December 22, 2005





In The

Court of Appeals

For The

First District of Texas





NOS. 01–05–00871–CV

          01–05–00872–CV





E.V.A., Appellant


V.


THE STATE OF TEXAS, Appellee





On Appeal from the Probate Court

Galveston County, Texas

Trial Court Cause Nos. 2655 and 2655A



MEMORANDUM OPINION


          In these two accelerated appeals, appellant, E.V.A., raises three issues challenging the trial court’s separate orders (1) that E.V.A. be involuntarily committed for temporary inpatient mental health services and (2) that she be administered psychoactive medications. E.V.A. contends that the evidence presented by the State at her commitment hearing is legally and factually insufficient to support the findings on which the order for temporary inpatient treatment is based. Concomitantly, E.V.A. also contends that the trial court’s order to administer psychoactive medication must be reversed because such an order cannot stand unless a proper order for inpatient mental health services is also in place.

          We affirm.

Background

          On August 5, 2005, E.V.A. was admitted to the University of Texas Medical Branch Hospital (“UTMB”). The medical records for that admission indicate that E.V.A. was brought to UTMB by the Galveston County sheriff’s department because “she got into an argument [with] a supervisor at work.”

          On August 22, 2005, Dr. Pasztor signed an application for court-ordered temporary mental health services, which was filed with the trial court. As applicant, Dr. Pasztor requested the trial court to involuntarily commit E.V.A. to the Austin State Hospital for a period not to exceed 90 days. The application was supported by two certificates of medical examination: one prepared by Dr. Pasztor and one by Dr. Jon Guidry. Both doctors stated that they had examined E.V.A. and diagnosed her with bipolar disorder. To support his opinion that E.V.A. needed to be temporarily committed, Dr. Guidry referred to E.V.A.’s statements that her family wants to kill her, E.V.A.’s refusal to take her medication, and the “frequent emergency injections” that E.V.A. had received “for aggression.” In his certificate of medical examination, Dr. Pasztor cited, inter alia, E.V.A.’s refusal to take her medication. Dr. Pasztor also wrote that E.V.A. had “induce[d] diarrhea” to “get rid of her meds.”

          E.V.A.’s commitment hearing was held on August 31, 2005. At the conclusion of the hearing, the trial court, as factfinder, made the following oral findings:

The Court finds that [E.V.A.] is mentally ill. As a result of that mental illness, she is likely to cause serious harm to others. She is suffering severe and abnormal mental, emotional, or physical distress and is experiencing substantial mental or physical deterioration of her ability to function independently. And she is unable to make a rational and informed decision as to whether or not to submit to treatment . . . .


As a result, the trial court signed an “Order For Temporary Inpatient Mental Health Services,” in which the trial court ordered E.V.A. committed to the Austin State Hospital for a period not to exceed 90 days.

          Immediately following the commitment hearing, the trial court conducted a hearing on the State’s application to administer psychoactive medication, which had been filed at the same time as the commitment application. At the conclusion of the hearing, the court signed an “Order to Administer Psychoactive Medication,” providing that certain classes of psychoactive medications could be administered to E.V.A. for the duration of her temporary commitment.

          E.V.A. appeals both the “Order For Temporary Inpatient Mental Health Services” and the “Order to Administer Psychoactive Medication.”

Order for Temporary Commitment

          In her first two issues, E.V.A. challenges the legal and factual sufficiency of the evidence supporting the Order For Temporary Inpatient Mental Health Services.

A.      Burden of Proof

          To obtain an order for temporary commitment, the Texas Legislature has mandated that the State must prove its case by clear and convincing evidence. See Tex. Health & Safety Code Ann. § 574.034 (Vernon 2003). In this context, “clear and convincing evidence” means “that measure or degree of proof which will produce in the mind of the trier of fact a firm belief or conviction as to the truth of the allegations sought to be established.” State v. Addington, 588 S.W.2d 569, 570 (Tex. 1979). Specifically, Health and Safety Code subsection 574.034(a) provides that the judge may order a proposed patient to receive court-ordered temporary inpatient mental health services only if the judge or a jury finds, from clear and convincing evidence, that:

          (1)     the proposed patient is mentally ill; and

          (2)     as a result of that mental illness the proposed patient:

(A)is likely to cause serious harm to himself;

                    (B)    is likely to cause serious harm to others; or

                    (C)    is:

(i)suffering severe and abnormal mental, emotional, or physical distress;

(ii)experiencing substantial mental or physical deterioration of the proposed patient’s ability to function independently, which is exhibited by the proposed patient’s inability, except for reasons of indigence, to provide for the proposed patient’s basic needs, including food, clothing, health, or safety; and

(iii)unable to make a rational and informed decision as to whether or not to submit to treatment.


Tex. Health & Safety Code Ann. § 574.034(a).



          Subsection 574.034(c) requires that, if the judge or a jury finds that the proposed patient meets the commitment criteria prescribed by subsection (a), the judge or the jury must specify which criterion listed in subsection (a)(2) forms the basis for that decision. Id. § 574.034(c). Our review is limited to the criteria actually identified. See Johnstone v. State

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Related

State for the Best Interest & Protection of C.O.
65 S.W.3d 175 (Court of Appeals of Texas, 2001)
State v. Addington
588 S.W.2d 569 (Texas Supreme Court, 1979)
JM v. State
178 S.W.3d 185 (Court of Appeals of Texas, 2005)
Johnstone v. State
961 S.W.2d 385 (Court of Appeals of Texas, 1997)
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M.S. v. State
137 S.W.3d 131 (Court of Appeals of Texas, 2004)

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