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

CourtCourt of Appeals of Iowa
DecidedApril 10, 2024
Docket23-1336
StatusPublished

This text of In the Matter of R.B., Alleged to Be Seriously Mentally Impaired (In the Matter of R.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 R.B., Alleged to Be Seriously Mentally Impaired, (iowactapp 2024).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 23-1336 Filed April 10, 2024

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

R.B., Respondent-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Marshall County, Bethany Currie,

Judge.

R.B. appeals the district court’s order finding him to be seriously mentally

impaired and determining his placement. AFFIRMED.

Laura A. Eilers of Peglow, O’Hare, See & Eilers, P.L.C., Marshalltown, for

appellant.

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

General, for appellee State.

Considered by Ahlers, P.J., Buller, J., and Gamble, S.J.*

*Senior judge assigned by order pursuant to Iowa Code section 602.9206

(2024). 2

GAMBLE, Senior Judge.

In July 2009, R.B. was found to be seriously mentally impaired, a

determination that has been confirmed regularly by evaluating psychiatrists. R.B.

is currently in residential care at the Iowa Veterans Home in Marshalltown. R.B.

appeals a district court order affirming he is seriously mentally impaired and his

placement. He challenges whether he continues to be seriously mentally impaired

and his current placement as the least-restrictive placement. “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

elements required for an involuntary commitment must be established by clear and

convincing evidence,” and we are bound by the district court’s fact findings “if

supported by substantial evidence.” In re V.H., 996 N.W.2d 530, 536 (Iowa 2023)

(citation omitted).

R.B. has appealed his commitment twice before. In 2014, he appealed his

placement at the Iowa Veterans Home; the district court and this court affirmed the

finding of continuing serious mental impairment and the placement. In re R.B.,

No. 15-0823, 2015 WL 6507836, at *1 (Iowa Ct. App. Oct. 28, 2015) (noting R.B.’s

condition was not improving at that time). Just over four years later, R.B. petitioned

for a writ of habeas corpus, which the district court and then this court denied. In

re R.B., No. 19-2044, 2020 WL 7021787, at *2 (Iowa Ct. App. Nov. 30, 2020). In

that case, while we recognized some evidence in R.B.’s favor regarding whether

he posed a danger to himself, substantial evidence in the form of an overt act of

his drinking eleven beers in thirty minutes and a history of not attending follow-up 3

mental-health appointments supported the district court’s conclusion R.B. was

likely to injure himself or others if released from commitment. Id. at *1-2.

A. Seriously Mentally Impaired.

Iowa Code section 229.1(22) (2023) defines “seriously mentally impaired”

as

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. d. Has a history of lack of compliance with treatment and any of the following applies: (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.

Our courts have broken this down into three elements: (1) a mental illness,

(2) judgment impairment as to treatment, and (3) a danger posed to self or others.

See V.H., 996 N.W.2d at 543. The danger posed is predictive in nature but must

“be evidenced by a recent overt act, attempt, or threat.” Id. (cleaned up). R.B.

only argues the danger element was not proven by clear and convincing evidence,

he does not challenge the other elements.

R.B. has been diagnosed with several mental-health issues—including

schizophrenia, anxiety, a neurocognitive disorder following a 2010 traumatic brain 4

injury, and others. He takes prescription medications to manage his symptoms.

R.B.’s medications are managed by a nurse practitioner in the Veterans Home,

and the Veterans Affairs (VA) psychiatrist reviews his records regularly. R.B. has

refused treatment with the VA’s psychiatrist since 2019 after the doctor continued

to recommend treatment at the Veterans Home instead of independent living. R.B.

stated the psychiatrist “gets me more depressed,” so he doesn’t bother talking to

him.

R.B. testified on his own behalf. Although he was unaware of the doses of

his medication, he stated he would comply with his medication to get out of the

facility. He appeared to believe his past alcohol abuse was the primary reason for

his placement at the Veterans Home. When questioned about his plans outside,

he mentioned fishing, hunting, and seeing his siblings. He agreed with one of his

prior statements that he would like to get an RV and travel across the country. 1

Even without the RV, R.B. planned to travel and see the country and visit family

and friends. He talked about writing letters to celebrities he is convinced are his

children and claimed to have “over ten” children.2

In July 2022, R.B. was evaluated by an independent psychiatrist in regards

to his continued commitment at the Veterans Home. He told the independent

psychiatrist he didn’t need his medications because he doesn’t have a mental

1 At a prior hearing, R.B. admitted his drivers license had lapsed and he had not

renewed it because he is not allowed a car at the Veterans Home. Nothing in the record indicates he has since gotten his license back. 2 At an earlier hearing, the VA psychiatrist attributed these beliefs to R.B. having

“residual effects from schizophrenia” despite the general effectiveness of his treatment. R.B.’s paranoia and delusions worsened for a time, leading to an increase in medication dosage in 2018. His dose has been stable since then. 5

illness. The evaluating psychiatrist recommended R.B. remain at the Veterans

Home as the least restrictive placement, noting his need for structure and opining

R.B. would not comply with his medication without supervision and likely injure

himself or others.

The VA psychiatrist testified, emphasizing the importance of a structured

environment and supervision for R.B.’s continued sobriety and medication

management. He opined if on his own, R.B. was likely to start using alcohol again,

which combined with his cognitive impairment would result in a failure to take

medication as prescribed, leaving him at risk for severe and unmanageable

delusions and hallucinations. Further, without adequate supervision, the

psychiatrist doubted R.B.

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