In Re Jm

CourtMichigan Court of Appeals
DecidedFebruary 17, 2026
Docket375538
StatusPublished

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

Bluebook
In Re Jm, (Mich. Ct. App. 2026).

Opinion

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to revision until final publication in the Michigan Appeals Reports.

STATE OF MICHIGAN

COURT OF APPEALS

In re JM.

MIZUKA YASUOKA, UNPUBLISHED February 17, 2026 Petitioner-Appellee, 9:48 AM

v No. 375538 Washtenaw Probate Court JM, LC No. 25-000189-MI

Respondent-Appellant.

Before: GADOLA, C.J., and BOONSTRA and PATEL, JJ.

PER CURIAM.

Respondent appeals as of right the probate court’s order requiring respondent to undergo involuntary mental-health treatment. We reverse.

I. BACKGROUND

Respondent moved from New Mexico to Michigan to join an unnamed spiritual or religious group. When she arrived in Michigan, she rented a car and began driving. While respondent was driving, she began to experience fear because of her phobias of bridges and water. She went to an emergency room hospital and voluntarily sought treatment because her mania, reduced sleep, and phobias were interfering with her ability to drive. A licensed professional counselor petitioned for involuntary mental-health treatment. The petition alleged that respondent was manic and that her phobias presented “a challenge.” It further alleged that respondent was homeless and that respondent reported moving from New Mexico to Michigan for a “spiritual community group.” A psychiatrist and physician filed reports with the petition that diagnosed respondent with mania and “bipolar disorder, current episode manic.” These reports also stated that respondent was unable to attend to her basic physical needs and was unwilling to participate in the necessary treatment.

Dr. Tomi Rumano, a board-certified psychiatrist and respondent’s treating doctor, testified at the hearing. Dr. Rumano diagnosed respondent with bipolar disorder with mania. In support of

-1- this diagnosis, Dr. Rumano testified that respondent was hyperverbal, hyperreligious, and had congenital thought process (jumps from topic to topic). When asked whether respondent could reasonably be expected to injure herself because of her mental illness, Dr. Rumano testified that respondent could be reasonably expected to “probably” unintentionally injure herself because she was “unable to take care of herself” and could “be taken advantage [of] by others.” No further explanation was offered. Dr. Rumano also testified that respondent “initially refused treatment” but then eventually agreed to take a lower level of lithium than recommended. However, respondent refused to take Abilify, an antipsychotic medication that Dr. Rumano believed was necessary to treat respondent’s disorder. Dr. Rumano offered no testimony regarding whether respondent presented a substantial risk of significant harm to herself or others.

Respondent also testified. She agreed that she had bipolar disorder but disagreed with the recommended treatment for her disorder. Respondent testified that she wanted treatment but did not want it to be in inpatient treatment.

Following respondent’s testimony, the probate court ruled that there was clear and convincing evidence that respondent was a “person requiring treatment” under MCL 330.1401(1)(c). The probate court specifically concluded that respondent’s current medications were not sufficient because “her sleep was reduced and her phobias kept increasing,” and respondent’s “judgment was so impaired that she lacked the understanding of the need for the treatment that is currently being described,” so respondent was unwilling to participate in the necessary treatment. The probate court also conclusively stated that respondent presented “a substantial risk of significant inadvertent physical or mental harm, primarily to herself, but also others.”

The probate court then entered an order that committed respondent to combined hospitalization and assisted outpatient treatment for no more than 180 days, with the first 60 days in the hospital. This appeal followed.

II. STANDARDS OF REVIEW

We review a probate court’s dispositional rulings for abuse of discretion. In re MAT, ___ Mich App ___, ___; ___ NW3d ___ (2024) (Docket No. 369255); slip op at 2. “An abuse of discretion occurs when the probate court chooses an outcome outside the range of reasonable and principled outcomes.” In re Portus, 325 Mich App 374, 381; 926 NW2d 33 (2018) (cleaned up). When a probate court makes an error of law, it necessarily abuses its discretion. Id. We review the factual findings underlying a probate court’s decision for clear error. Id. “A probate court’s finding is clearly erroneous when a reviewing court is left with a definite and firm conviction that a mistake has been made, even if there is evidence to support the finding.” Id. (cleaned up). Finally, we review issues of statutory interpretation de novo. Id.

III. ANALYSIS

Respondent argues that petitioner failed to establish by clear and convincing evidence that she was a “person requiring treatment” under MCL 330.1401(1)(c). We agree.

A proceeding seeking an order of involuntary mental-health treatment is generally referred to as a civil-commitment proceeding. In re Jestila, 345 Mich App 353, 356; 5 NW3d 362 (2023).

-2- “The Michigan Supreme Court has held that civil commitment statutes must be strictly complied with.” Id. at 358.

In general, a probate court may properly order a respondent to undergo involuntary mental- health treatment when it finds by clear and convincing evidence that the respondent was a “person requiring treatment” under MCL 330.1401. In re Londowski, 340 Mich App 495, 504-505; 986 NW2d 659 (2022), citing MCL 330.1400(f), MCL 330.1468(2), and MCL 330.1465. “Evidence is clear and convincing when it produces in the mind of the trier of fact a firm belief or conviction as to the truth of the allegations sought to be established.” In re MAT, ___ Mich App at ___; slip op at 6 (cleaned up).

In the present case, respondent was found to be a “person requiring treatment” under MCL 330.1401(1)(c), which provides that the term includes:

An individual who has mental illness, whose judgment is so impaired by that mental illness, and whose lack of understanding of the need for treatment has caused him or her to demonstrate an unwillingness to voluntarily participate in or adhere to treatment that is necessary, on the basis of competent clinical opinion, to prevent a relapse or harmful deterioration of his or her condition, and presents a substantial risk of significant physical or mental harm to the individual or others.

A “mental illness” is defined as “a substantial disorder of thought or mood that significantly impairs judgment, behavior, capacity to recognize reality, or ability to cope with the ordinary demands of life.” MCL 330.1400(g).

Respondent does not dispute that she has a mental illness. Instead, respondent argues that petitioner failed to establish by clear and convincing evidence that she lacked an understanding of the need for treatment and that she presented a substantial risk of significant harm. We address each argument in turn.

The probate court found that respondent lacked the understanding of the need for recommended treatment and, therefore, was unwilling to participate in the necessary treatment. The statute states that “necessary treatment” is treatment that is based on a competent clinical opinion and needed to prevent relapse or harmful deterioration. MCL 330.1401(1)(c); see also MCL 330.1400(b). Respondent does not dispute that Dr. Rumano provided a competent clinical opinion; instead, she argues that Dr. Rumano did not explain why the recommended treatment was necessary to prevent a relapse. We disagree.

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Related

Mericka v. Department of Community Health
770 N.W.2d 24 (Michigan Court of Appeals, 2009)
People of Michigan v. Samer Shami
912 N.W.2d 526 (Michigan Supreme Court, 2018)
People v. Portus (In Re Portus)
926 N.W.2d 33 (Michigan Court of Appeals, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
In Re Jm, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-jm-michctapp-2026.