In the Interest of N.L., Alleged to Be Seriously Mentally Impaired, N.L.

CourtCourt of Appeals of Iowa
DecidedJune 15, 2016
Docket16-0094
StatusPublished

This text of In the Interest of N.L., Alleged to Be Seriously Mentally Impaired, N.L. (In the Interest of N.L., Alleged to Be Seriously Mentally Impaired, N.L.) is published on Counsel Stack Legal Research, covering Court of Appeals of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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In the Interest of N.L., Alleged to Be Seriously Mentally Impaired, N.L., (iowactapp 2016).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 16-0094 Filed June 15, 2016

IN THE INTEREST OF N.L., Alleged to be seriously mentally impaired,

N.L., Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Polk County, Rebecca Goodgame

Ebinger, Judge.

A man appeals his involuntary civil commitment. REVERSED AND

REMANDED.

Alexander D. Smith of Parrish, Kruidenier, Dunn, Boles, Gribble, Gentry,

Brown & Bergman, L.L.P., Des Moines, for appellant.

Thomas J. Miller, Attorney General, and Gretchen Kraemer, Assistant

Attorney General, for appellee.

Considered by Potterfield, P.J., and Mullins and McDonald, JJ. 2

MCDONALD, Judge.

A magistrate judge civilly committed N.L. for psychiatric evaluation and

treatment pursuant to Iowa Code chapter 229 (2015). Three days later, the

evaluating doctor filed a discharge report, concluding N.L. did not require full time

hospitalization. Nonetheless, N.L. appealed the commitment order because of

the collateral consequences related to a finding he was seriously mentally

impaired within the meaning of chapter 229. See In re B.B., 826 N.W.2d 425,

429 (Iowa 2013) (holding “that a party who has been adjudicated seriously

mentally impaired and involuntarily committed is presumed to suffer collateral

consequences justifying appellate review”). Following trial de novo, 1 the district

court issued a hospitalization order placing N.L. at a medical facility for

psychiatric evaluation and treatment on an outpatient basis. N.L. timely filed this

appeal.

“An involuntary civil commitment proceeding is a special action that is

triable to the court as an action at law.” In re B.T.G., 784 N.W.2d 792, 796 (Iowa

Ct. App. 2010). Challenges to the sufficiency of the evidence in involuntary

commitment proceedings are reviewed for correction of errors at law. See Iowa

R. App. P. 6.907; B.B., 826 N.W.2d at 428. The allegations in an application for

1 There are significant differences between a “trial de novo” and a “de novo review.” See In re Huston, 263 N.W.2d 697, 699 (Iowa 1978). Generally, in a “de novo review” proceeding, the reviewing court is restricted to the record made in the lower tribunal. Sieg v. Civil Serv. Comm’n, 342 N.W.2d 824, 828 (Iowa 1983); Mason v. World War II Serv. Compensation Bd., 51 N.W.2d 432, 434 (Iowa 1952). On the other hand, “in a trial de novo, the court hearing the case anew is permitted to receive evidence additional to that presented” in the earlier hearing. Dolan v. Civil Serv. Comm’n, 634 N.W.2d 657, 662 (Iowa 2001); see also Mason, 51 N.W.2d at 434. Therefore, a statute providing for a “trial de novo” in the district court contemplates a trial in the general meaning of the term, not merely a review of the agency proceeding. Dolan, 634 N.W.2d at 662; see also In re S.P., 719 N.W.2d 535, 536 (Iowa 2006). 3

involuntary commitment must be proved by clear and convincing evidence. See

In re J.P., 574 N.W.2d 340, 342 (Iowa 1998). For evidence to be clear and

convincing “there must be no serious or substantial doubt about the correctness

of a particular conclusion drawn from the evidence.” Id.

To support an involuntary commitment under Iowa Code chapter 229, the

applicant must prove by clear and convincing evidence the person is “seriously

mentally impaired” or has a “serious mental impairment” as defined in section

229.1(20). That definition provides:

“Seriously mentally impaired” or “serious mental impairment” describes the condition of a person with mental illness and because of that illness lacks sufficient judgment to make responsible decisions with respect to the person’s hospitalization or treatment, and who because of that illness meets any of the following criteria: a. Is likely to physically injure the person’s self or others if allowed to remain at liberty without treatment. b. Is likely to inflict serious emotional injury on members of the person’s family or others who lack reasonable opportunity to avoid contact with the person with mental illness if the person with mental illness is allowed to remain at liberty without treatment. c. Is unable to satisfy the person’s needs for nourishment, clothing, essential medical care, or shelter so that it is likely that the person will suffer physical injury, physical debilitation, or death.

N.L. challenges the sufficiency of the evidence supporting the second

element—that because of his illness he lacked judgmental capacity regarding his

hospitalization or treatment. This element “requires the State to prove that the

person is unable, because of the alleged mental illness, to make a rational

decision about treatment, whether the decision is to seek treatment or not.”

Matter of Mohr, 383 N.W.2d 539, 541 (Iowa 1986). In determining whether the

person can make a rational decision, “the focus must be on whether the grounds

for the decision are rational or reasonable not what conclusion is reached.” J.P., 4

574 N.W.2d at 343. “A decision, although medically inadvisable, may be

rationally reached, and if so, it is not the court’s place to second guess the

decision.” Id.

We conclude there is not substantial evidence supporting the finding N.L.

lacked judgmental capacity regarding his hospitalization or treatment. In the

discharge report, the evaluating and treating doctor diagnosed N.L. with major

depressive disorder, recurrent. The doctor concluded N.L. was “capable of

making responsible decisions with respect to his hospitalization or treatment.”

The doctor also stated N.L. “has improved with treatment, understands his

mental disorders and accepts all treatment recommendations.” The doctor

concluded N.L. was treatable. At trial, the same doctor testified as follows:

Q. All right. Doctor, once again, based upon your history and physical and upon a reasonable degree of certainty within your profession, as well as your own personal observations and laboratory studies, were you able to formulate an opinion as to whether or not [N.L.] is capable of making responsible decisions with respect to his hospitalization or treatment? A. As of his most recent evaluation done by me, which was two days ago, I think he’s capable of making decisions. Q. All right. Let me ask you this, Doctor: If he has a recurrent condition and if he has a situation that we cannot predict, is it likely that in the future he would not have judgmental capacity? A. As I said, the likelihood of relapse or recurrence without treatment would be significant. The risk is mitigated if he is complying with treatment.

There was no medical testimony or other expert opinion to the contrary.

In reaching a contrary finding, the district court relied on the testimony of a

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Related

Sieg v. CIV. SERV. COM'N OF WEST DES MOINES
342 N.W.2d 824 (Supreme Court of Iowa, 1983)
Mason v. World War II Service Compensation Board
51 N.W.2d 432 (Supreme Court of Iowa, 1952)
In Re the Marriage of Huston
263 N.W.2d 697 (Supreme Court of Iowa, 1978)
In the Interest of J.P.
574 N.W.2d 340 (Supreme Court of Iowa, 1998)
Dolan v. CIVIL SERVICE COM'N OF DAVENPORT
634 N.W.2d 657 (Supreme Court of Iowa, 2001)
Matter of Mohr
383 N.W.2d 539 (Supreme Court of Iowa, 1986)
In re B.T.G.
784 N.W.2d 792 (Court of Appeals of Iowa, 2010)

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