In the Matter of the Civil Commitment of J.P.

CourtNew Jersey Superior Court Appellate Division
DecidedMay 8, 2024
DocketA-1238-22
StatusUnpublished

This text of In the Matter of the Civil Commitment of J.P. (In the Matter of the Civil Commitment of J.P.) 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 J.P., (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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-1238-22

IN THE MATTER OF THE CIVIL COMMITMENT OF J.P.1

Argued February 14, 2024 – Decided May 8, 2024

Before Judges Currier and Firko.

On appeal from the Superior Court of New Jersey, Law Division, Mercer County, Docket No. MECC00094522.

Vanessa Fiore, Assistant Deputy Public Defender, argued the cause for appellant J.P. (Jennifer Nicole Sellitti, Public Defender, attorney; Vanessa Fiore and Cynthia Seda-Schreiber, Deputy Public Defender, on the briefs).

Michael Anthony Amantia, Assistant County Counsel, argued the cause for respondent State of New Jersey (Paul R. Adezio, Mercer County Counsel, attorney; Michael Anthony Amantia, on the brief).

PER CURIAM

1 We use initials pursuant to Rule 1:38-3(f)(2). Appellant J.P. appeals from the November 16, 2022 civil commitment

order that continued his involuntary commitment and denied his request to

convert to voluntary admission status. The court found J.P. did not have the

capacity to make an informed decision regarding a change to his status as

required under Rule 4:74-7(g)(1). We affirm.

J.P. was admitted to Capital Health Regional Medical Center on October

21, 2022 after attempting to commit suicide by jumping in front of an oncoming

train. The severe injuries required the amputation of both legs.

J.P. had prior diagnoses of bipolar mood disorder, multiple sclerosis,

cannabis use disorder, and chronic alcohol abuse. He had been hospitalized

multiple times between July 2022 and these events in October 2022. In July

2022, J.P. ingested anti-freeze and received inpatient psychiatric care for

approximately one month. In August, he was admitted to Capital Health for

inpatient psychiatric care after voicing suicidal thoughts about planning to jump

in front of a train. He was also treated at other facilities. J.P. was last admitted

to the hospital approximately a week before these events.

After the October 21, 2022 admission, J.P. was screened regarding his

mental health status and two psychiatrists completed certificates for his

involuntary commitment—Nayan Bhatia, M.D., and Mohammad M. Bari, M.D.

A-1238-22 2 During the screening, J.P. stated he had been living at the Rescue Mission,

and he went to the train station to take his life. He did not know if he was

intoxicated and "only remember[ed] waking up in the hospital with both legs

amputated."

Dr. Bhatia indicated in his certificate that J.P. expressed "[s]uicidal

ideation with no specific plan at this time," and his insight and judgment were

poor. Dr. Bhatia concluded that J.P. was dangerous to himself because of his

suicide attempt, his continued suicidal ideation, and his inability to satisfy his

essential medical care and shelter needs because he was "depressed" and "unable

to take care of [him]self due to decompensated psychiatric illness." Dr. Bhatia

recommended inpatient care.

Dr. Bari found that J.P. exhibited "unpredictable" and "impulsive

behavior." He also found J.P.'s insight and judgment were poor, and he would

be a danger to himself because of his suicide attempt and his inability to satisfy

his essential medical care and shelter needs. He recommended that J.P. receive

inpatient psychiatric care.

The court ordered J.P. be temporarily involuntarily committed to Capital

Health. During the initial hearing on November 16, 2022, J.P. requested his

A-1238-22 3 status be converted to a voluntary commitment. County Counsel opposed the

application.

At the hearing, Dr. Bhatia testified that J.P. understood he struggled with

depression, and acknowledged he did not complete outpatient treatment or take

his medication after being discharged from hospitalizations. Dr. Bhatia noted

the prescribed medications had not been effective and despite his

hospitalizations, J.P. had not improved. Dr. Bhatia considered J.P. a danger to

himself because of his suicidal ideations and attempts. J.P. did not have a family

support system and continued to voice suicidal thoughts. Dr. Bhatia thought

that J.P. understood the need for psychiatric treatment, but he did not understand

the consequences of not taking his medication.

On cross-examination, Dr. Bhatia acknowledged J.P. had been diagnosed

with bipolar mood disorder but said "[i]t hasn't been fully established that he has

bipolar [mood] disorder. . . . It's still a work in progress as to what exactly his

diagnosis is." Dr. Bhatia stated that J.P. wanted to try Electroconvulsive

Therapy (ECT), although the doctor was not sure how much J.P. knew about

ECT. According to the doctor, J.P. could not answer why he stopped taking his

medication after prior discharges, but he had expressed the desire to continue

treatment.

A-1238-22 4 During J.P.'s testimony, he stated he did not follow up with his treatment

or medications after being discharged, although he would seek treatment again.

J.P. stated his brother supported him "[i]n a way," but did not provide any

details. J.P. confirmed he wanted to try ECT.

On cross-examination, J.P. admitted he did not know where he would be

living in thirty or forty days. He conceded that even though he was able to fill

his prescriptions while he was living at the Rescue Mission, he did not continue

taking them. J.P. said he knew that if he did not take his medication, he "would

go back to square one"; however, he felt his condition had not improved with

the medicine. He stated he still felt depressed and had suicidal thoughts when

taking the medication and he did not think that stopping the prescriptions would

make a difference.

The court issued an oral decision, finding that J.P. satisfied the criteria for

involuntary commitment and was a danger to himself "based upon the recent

incidents and the prior suicide attempts." The court stated J.P. did not have "the

capacity to make the determination regarding his continued health treatment in

the hospital." The court noted J.P. had suicidal ideations, had attempted to

commit suicide which resulted in the amputation of his legs, and that he did not

A-1238-22 5 comprehend the consequences of not taking his medication. The court

memorialized its decision in a November 16, 2022 order.

On appeal, J.P. contends the court erred in denying his application for a

conversion to voluntary commitment as the State did not prove he lacked

capacity to make the determination regarding his commitment status.

Rule 4:74-7 governs the civil commitment of adults. "[A]ppellate review

of a commitment determination is extremely narrow and should be modified

only if the record reveals a clear mistake." In re D.C., 146 N.J. 31, 58 (1996).

We give the "utmost deference" to a trial court's decision and only modify it if

there was an abuse of discretion. In re Commitment of J.P., 339 N.J. Super. 443,

459 (App. Div. 2001) (quoting State v. Fields, 77 N.J. 282, 311 (1978)). As

long as the trial court made "supportable findings," its decision should be

affirmed. In re Commitment of T.J., 401 N.J. Super. 111, 119 (App. Div. 2008).

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Related

In Re Commitment of Tj
949 A.2d 286 (New Jersey Superior Court App Division, 2008)
State v. Fields
390 A.2d 574 (Supreme Court of New Jersey, 1978)
In Re Applications for the Commitment of Sl
462 A.2d 1252 (Supreme Court of New Jersey, 1983)
In re M.D.
596 A.2d 766 (New Jersey Superior Court App Division, 1991)
In re the Commitment of J.P.
772 A.2d 54 (New Jersey Superior Court App Division, 2001)

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In the Matter of the Civil Commitment of J.P., Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-matter-of-the-civil-commitment-of-jp-njsuperctappdiv-2024.