In re T.C.

• Court: Court of Appeals of Iowa
• Decided: May 21, 2025
• Docket: 24-1525
• Status: Published

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 24-1525 Filed May 21, 2025

IN THE MATTER OF T.C., ALLEGED TO BE SERIOUSLY MENTALLY IMPAIRED,

T.C., Respondent-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Des Moines County,

Joshua P. Schier, Judge.

T.C. appeals the district court’s order continuing his residential treatment.

AFFIRMED.

Ryan D. Gerling of Cray Law Firm, PLC, Burlington, for appellant.

Brenna Bird, Attorney General, and Sarah Anne Jennings, Assistant

Attorney General, for appellee State.

Considered without oral argument by Tabor, C.J., and Schumacher and

Chicchelly, JJ. 2

CHICCHELLY, Judge.

T.C. appeals the district court’s order continuing his residential treatment.

Upon our review, we affirm.

I. Background Facts and Proceedings.

In February 2021, the Burlington Police Department brought T.C. to the

emergency department after officers found him directing traffic wearing clothing

inappropriate for the cold weather. A month later, T.C. was arrested for disorderly

conduct after flagging down cars on the street and “lying face down on the

pavement.” These incidents sparked involuntary-commitment proceedings, which

spanned nearly four years.

From early 2021 to late 2024, T.C. cycled in and out of court-ordered

treatment. Most outpatient stays lasted a few weeks or months before he returned

to residential treatment. But even while residing in treatment, T.C. made limited

improvements. His medical providers described him as refusing to comply with

medication recommendations and behaving erratically, including verbal outbursts

and throwing a chair. T.C. also eloped several times, hitchhiking to gas stations

to purchase alcohol and cigarettes. One month before the review hearing, T.C.

eloped four times in one week alone. Around the same time, T.C.’s social worker

testified he told her “George W. Bush wants him to kill himself.” And even just one

week before the hearing, T.C. was still suffering from delusions, in which he had

conversations with himself.

In September 2024, a review hearing occurred, after which the court

ordered T.C. to continue residential treatment. It also granted the treatment facility 3

the authority to “administer the medications they feel appropriate to [T.C.] over

objection if necessary.” T.C. only appeals the continued placement.

II. Review.

Our review of involuntary-committal proceedings is for correction of errors

at law. See In re B.T.G., 784 N.W.2d 792, 796 (Iowa Ct. App. 2010). “The district

court’s findings of fact are binding upon this court if supported by substantial

evidence.” Id. “Evidence is substantial if a reasonable trier of fact could conclude

the findings were established by clear and convincing evidence.” Id.

III. Discussion.

T.C. vaguely argues that his placement option does not comply with Iowa

Code section 229.23.1 See Iowa Code § 229.23 (2024) (entitling individuals

“hospitalized or detained under this chapter” to certain enumerated rights). To

support this contention, T.C. cites his lack of progress in residential treatment

despite the significant length of time spent there. But we find the court did not err

in finding his current placement was the best option. The record is replete with

evidence that T.C. is not stable enough for outpatient treatment. T.C. admits in his

own brief that he “has possibly gotten worse” since returning to inpatient treatment,

and based on the testimonies, his medical providers agree. The facility’s Associate

Medical Director testified that if T.C. cannot be properly stabilized, he may even

need a higher level of care. In the weeks leading up to the hearing, T.C. continued

to suffer from delusions and absconded from treatment. The court found that even

1 It is unclear what relief T.C. requests. While at the review hearing he requested transfer to an outpatient program, his brief suggests a higher level of care is necessary. For the reasons discussed below, we find neither option appropriate. 4

T.C.’s own testimony at the review hearing, in which he struggled to follow

questioning and spoke over counsel, indicated his instability. We therefore find

that substantial evidence supports the court’s finding that he cannot return to

outpatient treatment at this time.

But even so, we do not find the court erred by not transferring him to a

higher level of care either. “It is not only the customary procedure, but the

constitutionally and statutorily mandated requirement, to treat even seriously

mentally impaired persons in the least restrictive environment medically possible.”

In re R.B., No. 23-1336, 2024 WL 1553808, at *3 (Iowa Ct. App. Apr. 10, 2024)

(citation omitted). While T.C.’s medical providers testified they had considered

transfer, nothing could occur until T.C. complied with referral procedures. To

alleviate issues stemming from T.C.’s refusal to comply with recommendations,

the court authorized the facility to administer medications over his objections.

Presumably, this was done in the hope that T.C. would receive proper medication

management, improve, and then become eligible for transfer to another level if

necessary. We do not find this decision to be error, but sound protection of T.C.’s

rights. Substantial evidence similarly supports this finding, so we affirm.

IV. Disposition.

Because there is substantial evidence supporting the court’s findings, we

affirm.