In the Matter of the Civil Commitment of A.E.

CourtNew Jersey Superior Court Appellate Division
DecidedFebruary 21, 2024
DocketA-1667-22
StatusUnpublished

This text of In the Matter of the Civil Commitment of A.E. (In the Matter of the Civil Commitment of A.E.) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In the Matter of the Civil Commitment of A.E., (N.J. Ct. App. 2024).

Opinion

RECORD IMPOUNDED

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-1667-22

IN THE MATTER OF THE CIVIL COMMITMENT OF A.E. ________________________

Argued February 12, 2024 – Decided February 21, 2024

Before Judges Mawla and Vinci.

On appeal from the Superior Court of New Jersey, Law Division, Camden County, Docket No. MNCC-000047-23.

Brian P. Hughes, Assistant Deputy Public Defender, argued the cause for appellant A.E. (Jennifer Nicole Sellitti, Public Defender, attorney; Brian P. Hughes, on the briefs).

Matthew White, Assistant County Counsel, argued the cause for respondent State of New Jersey (Emeshe Arzón, Camden County Counsel, attorney; Krista Ayn Schmid, Assistant County Counsel, on the brief).

PER CURIAM A.E. appeals from the January 26, 2023 order that continued his

involuntary commitment. Based on our review of the record and applicable

principles of law, we affirm.

On January 9, 2023, A.E., who was sixty years old at the time, was

admitted to Northbrook Behavioral Health Hospital ("Northbrook") in Camden

suffering from acute unspecified psychotic disorder. A.E. was experiencing

delusions that he was paralyzed. His delusions began after he saw a player

sustain an injury while watching a professional football game. On January 10,

2023, a judge entered a temporary order for involuntary commitment. On

January 26, 2023, the court conducted a commitment hearing. A.E. applied for

immediate discharge. He did not seek Conditional Extension Pending

Placement ("CEPP").

Dr. Thomas Campo, A.E.'s treating psychiatrist at Northbrook, testified

for the State, and recommended continuing involuntary commitment. Dr.

Campo testified A.E. was suffering from a mental illness, unspecified psychotic

disorder. At the time of the hearing, A.E. was still experiencing delusions that

he had previously been paralyzed but was "somewhat recovered" and suffering

"vestigial weaknesses." According to Dr. Campo, A.E. believed "if he [was] on

the floor, his limitations [would not] allow him to get up by himself, [and] he

A-1667-22 2 [would have] to remain on the floor." During his stay at Northbrook, hospital

staff did, in fact, need to help him up from the floor.

A.E. was not suffering from any medical or neurocognitive issues that

would cause paralysis or weakness. Dr. Campo was treating A.E. with Risperdal

and Gabapentin. Dr. Campo testified A.E. was medication compliant, but A.E.

believed he did not need medication. A.E. also believed he needed a defibrillator

implanted to help with his medical issues.

Dr. Campo testified A.E. could not attend to his necessary activities of

daily living, including general hygiene, without assistance in the hospital due,

in part, to his delusions. Dr. Campo testified A.E. had poor insight into his

mental illness and believed he was being treated for a medical condition causing

his paralysis and weakness.

Although A.E. desired to return to his elderly parents' home where he lived

since 1973, his parents advised Northbrook they would not allow him to return

until he was stable. Dr. Campo testified that returning A.E. to his parents' home

when he was ready was a better option than alternative housing. He explained

no less restrictive environment was appropriate at the time, and A.E. was an

imminent danger to himself due to his inability to care for himself because of

his mental illness. Specifically, Dr. Campo opined that if A.E. was released

A-1667-22 3 immediately, he would need to go to an emergency shelter and would end up in

the emergency room by the end of the day because of his delusions. Dr. Campo

believed A.E. was "getting better" and expected A.E. would be released in

"another week or so."

A.E. testified he had "a condition in [his] spine. It hits [his] peroneal

nerve, so [he] can't get down on the floor and get back up. [He has] to be by a

chair. [He] didn't fall down getting up. Nobody helps [him], in [Northbrook],

[to] get back up." A.E. also testified, contrary to Dr. Campo's testimony, he

showered regularly and cared for himself at Northbrook and never needed

assistance to get up from the floor.

Based on Dr. Campo's testimony and written report, the court found the

State proved by clear and convincing evidence A.E. suffered from a mental

illness, unspecified psychotic disorder. The court also found A.E. suffered "a

delusional incident where he believed himself to become paralyzed. He ha[d]

since regained some mobility, but he still believe[ed] that if he [was] on the

ground, he [could] not stand up." The court noted there was no evidence A.E.

had a source of income and found A.E. had no place to live other than his parents'

home, which was not available to him until his condition improved. It found

A.E. would not be able to survive outside the hospital because he would not have

A-1667-22 4 a place to live, be able to obtain food, or care for himself. The court concluded

A.E. "in his present situation" was not "able to negotiate the basic requirements

of life and be able to care for himself." It ordered continued involuntary

commitment and scheduled a review hearing for February 16, 2023. On

February 7, 2023, A.E. was released.

On appeal, A.E. argues the court erred in not ordering CEPP. In his reply

brief, A.E. also argues the State failed to meet its burden to establish involuntary

commitment was appropriate. More particularly, A.E. argues the State failed to

establish by clear and convincing evidence it was probable he would suffer

substantial bodily injury within the foreseeable future.

We review the decision to continue an individual's civil commitment

utilizing an abuse of discretion standard. See In re D.C., 146 N.J. 31, 58-59

(1996). When reviewing civil commitment decisions, "we afford deference to

the trial court's supportable findings." In re Commitment of T.J., 401 N.J. Super.

111, 119 (App. Div. 2008). We "reverse[] only when there is clear error or

mistake." In re Commitment of M.M., 384 N.J. Super. 313, 334 (App. Div.

2006). However, we "must consider the adequacy of the evidence." Ibid.

To continue an individual's involuntary commitment after a temporary

commitment order, a court must find "by clear and convincing evidence

A-1667-22 5 presented at [a] hearing that the patient is in need of continued involuntary

commitment . . . ." R. 4:74-7(f)(1). The Legislature has defined this to mean:

that an adult with mental illness, whose mental illness causes the person to be dangerous to self or dangerous to others or property and who is unwilling to accept appropriate treatment voluntarily after it has been offered, needs outpatient treatment or inpatient care at a short-term care or psychiatric facility or special psychiatric hospital because other services are not appropriate or available to meet the person's mental health care needs.

[N.J.S.A. 30:4-27.2(m).]

A person is "dangerous to self" if:

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Related

In Re Commitment of Tj
949 A.2d 286 (New Jersey Superior Court App Division, 2008)
In Re Commitment of MM
894 A.2d 1158 (New Jersey Superior Court App Division, 2006)
In Re Applications for the Commitment of Sl
462 A.2d 1252 (Supreme Court of New Jersey, 1983)

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