In the Matter of C.B., Alleged to Be Seriously Mentally Impaired

CourtCourt of Appeals of Iowa
DecidedApril 26, 2023
Docket22-2089
StatusPublished

This text of In the Matter of C.B., Alleged to Be Seriously Mentally Impaired (In the Matter of C.B., Alleged to Be Seriously Mentally Impaired) 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 Matter of C.B., Alleged to Be Seriously Mentally Impaired, (iowactapp 2023).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 22-2089 Filed April 26, 2023

IN THE MATTER OF C.B., Alleged to Be Seriously Mentally Impaired,

C.B., Respondent-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Woodbury County, Robert D.

Tiefenthaler, Judge.

C.B. appeals the district court finding he is seriously mentally impaired.

AFFIRMED.

Debra S. De Jong of De Jong Law Firm, P.C., Orange City, for appellant.

Brenna Bird, Attorney General, and Sarah A. Jennings, Assistant Attorney

General, for appellee State.

Considered by Bower, C.J., and Badding and Buller, JJ. 2

BOWER, Chief Judge.

C.B. appeals an order of noncompliance finding him seriously mentally

impaired, challenging the sufficiency of the evidence. We affirm.

“We review challenges to the sufficiency of the evidence in involuntary

commitment proceedings for errors at law.” In re B.B., 826 N.W.2d 425, 428 (Iowa

2013). “The allegations made [in support of] involuntary commitment must be

proven by clear and convincing evidence.” Id. In other words, “there must be no

serious or substantial doubt about the correctness of a particular conclusion drawn

from the evidence.” Id. (citation omitted).

To find a person seriously mentally impaired, “that person must first be

found to be ‘afflicted with a mental illness,’ and consequently ‘to lack sufficient

judgment to make responsible decisions with respect to his or her hospitalization

or treatment.’” Id. at 432 (citation omitted); see Iowa Code § 229.1(21) (Supp.

2022). And, because of their illness, the person must also be found to meet 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. d. Has a history of lack of compliance with treatment and any of the following apply: (1) Lack of compliance has been a significant factor in the need for emergency hospitalization. (2) Lack of compliance has resulted in one or more acts causing serious physical injury to the person’s self or others or an attempt to physically injure the person’s self or others. 3

Iowa Code § 229.1(21).

On August 26, 2022, C.B.’s mother filed an application alleging serious

mental impairment and requesting his hospitalization. The application stated C.B.

had auditory hallucinations, outbursts with swearing and sometimes violence, self-

isolation behaviors, paranoia, and an inability to maintain his home or pay his bills.

She also asserted C.B. had been involuntarily released from school. C.B.’s father

provided a supporting affidavit corroborating concerns about C.B.’s paranoia,

auditory hallucinations, and the possibility he might hurt himself or others.

Based on the application and supporting affidavit, the court ordered C.B.

into medical custody and appointed a physician to examine C.B. The physician

diagnosed C.B. with a schizophrenia spectrum disorder and stated C.B. lacked

sufficient judgment to make responsible treatment decisions during periods of

impairment. The physician determined C.B. was likely to physically injure himself

or others and was unable to satisfy his personal needs due to the mental illness.

The doctor cited self-harm elements of C.B.’s auditory hallucinations, fluctuating

stability, and reliance on family support for housing and finances. The physician

found C.B. to be seriously mentally impaired and recommended therapy and a

neurological review.

Following a hearing on September 1, the court found C.B. to be seriously

mentally impaired and ordered C.B. to participate in outpatient placement for

evaluation and treatment. C.B. was ordered “to follow all treatment

recommendations . . . including taking any medication recommended by the

provider.” At his intake evaluation, the treating advanced registered nurse

practitioner (ARNP) found C.B. not capable of making responsible treatment 4

decisions and opined his mental health would continue to decline without proper

treatment, including outpatient medication management. The evaluating ARNP

suggested injectable medication might be necessary due to C.B.’s lack of insight

into treatment.

A periodic report filed November 17 noted C.B. had not started the

recommended medications, he was paranoid of others, and his “mental health

seems to be deteriorating.” C.B. had not held down a job the prior two months and

was unable to obtain food or manage his medical needs. The reviewing ARNP

considered C.B. seriously mentally impaired and in need of inpatient treatment and

injectable medication to improve his prognosis. The report included an observation

C.B. had been evaluated by professionals in other fields of medicine who

confirmed his diagnosis. The district court ordered C.B. back into custody for

treatment. C.B. was picked up, and a noncompliance hearing was scheduled for

December 12.

A physician from a different facility evaluated C.B. before the hearing. The

doctor found C.B. had a mental illness, would benefit from additional time in the

hospital for stabilization and medication, and was not capable of making

responsible treatment decisions as shown by his refusing medication. The doctor

also stated C.B. had no insight into his illness and posed a danger to himself and

others as demonstrated by threats made against his former school. The doctor

found C.B. had a history of noncompliance with treatment and noted he refused

medications and mental health treatment.

At the noncompliance hearing, the parties accepted the physician’s report

in lieu of live testimony. C.B., his mother, his father, and a mental health advocate 5

testified. C.B.’s mother testified about seeing C.B.’s symptoms worsen over the

past year and her understanding of a recent incident where police were notified of

C.B. making threats against his former school on social media the day before the

hearing.1 She discussed purchasing all his groceries, needing to manage his bills,

and C.B.’s recent accrual of multiple driving violations. C.B.’s father mentioned his

fear that C.B. does not remember some of his actions after the fact.

When C.B. testified, he opined he had been wrongly diagnosed. He claimed

a religious belief that rejected the recommended medications and mental illness in

general. He testified using ear plugs muffled the voices he hears, so they must be

external. As to caring for himself, C.B. testified he could do his shopping and pay

the bills, but his mother later clarified he did not do so. He misses medical

appointments despite written reminders from his mother, and only goes to therapy

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Related

Matter of Foster
426 N.W.2d 374 (Supreme Court of Iowa, 1988)
In the Interest of J.P.
574 N.W.2d 340 (Supreme Court of Iowa, 1998)

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