Peo in Interest of Harden

• Court: Colorado Court of Appeals
• Decided: October 16, 2025
• Docket: 25CA1637
• Status: Unpublished

Opinion

25CA1637 Peo in Interest of Harden 10-16-2025

COLORADO COURT OF APPEALS

Court of Appeals No. 25CA1637 Mesa County District Court No. 25MH30123 Honorable Gretchen B. Larson, Judge

The People of the State of Colorado,

Petitioner-Appellee,

In the Interest of Sara Harden,

Respondent-Appellant.

ORDER AFFIRMED

Division V Opinion by JUDGE YUN Freyre and Pawar, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced October 16, 2025

Todd M. Starr, County Attorney, Richard B. Tuttle, Assistant County Attorney, Grand Junction, Colorado, for Petitioner-Appellee

Tezak Law, P.C., Mary Tezak, Florence, Colorado, for Respondent-Appellant ¶1 Sara Harden appeals the district court’s order authorizing the

involuntary administration of medications under the four-part

standard set forth in People v. Medina, 705 P.2d 961 (Colo. 1985).

She contests the sufficiency of the evidence only as to the second

Medina element. We conclude that sufficient evidence supports this

element. Accordingly, we affirm.

I. Background

¶2 In July 2025, Harden was placed on an emergency mental

health hold after exhibiting symptoms of psychosis following

emergency surgery to repair a perforated gastric ulcer brought on

by the overuse of nonsteroidal anti-inflammatory drugs (NSAIDs).

Doctors believed that her NSAID overuse was due to a psychotic

process. She was certified for short-term mental health treatment

at HCA HealthONE Mental Health and Wellness Center at the

Medical Center of Aurora (the hospital), where she denied taking

any NSAIDs and instead claimed her medical event was caused by

her “grandfather’s plutonium” and a “utensil.” Based on these

statements and a multi-year history of other psychotic symptoms

provided by Harden’s family, her treating psychiatrist, Dr. DeLeon,

1 diagnosed her with schizophrenia or schizophrenia spectrum

illness.

¶3 After Harden repeatedly declined antipsychotic medications,

the hospital sought authorization for their involuntary

administration. Because Harden had no prior history of taking

such medications, Dr. DeLeon requested three antipsychotic

medications — namely, olanzapine (Zyprexa), aripiprazole (Abilify),

and paliperidone (Invega). Dr. DeLeon also requested three

medications to address potential side effects: lorazepam (Ativan),

benzatropine (Cogentin), and diphenhydramine (Benadryl).

¶4 After a hearing, at which both Dr. DeLeon and Harden

testified, the district court entered an order authorizing the

requested medications pursuant to Medina.

II. Legal Principles and Standard of Review

¶5 A district court may authorize the involuntary administration

of medication if the petitioning party establishes each of the

following elements by clear and convincing evidence: (1) the person

is incompetent to effectively participate in the treatment decision;

(2) the treatment is necessary to prevent a significant and likely

long-term deterioration in the person’s mental health condition or

2 to prevent the likelihood of the patient causing serious harm to

herself or others in the institution; (3) a less intrusive treatment

alternative is not available; and (4) the person’s need for treatment

is sufficiently compelling to override any bona fide and legitimate

interest of the person in refusing treatment. Id. at 973.

¶6 We assess whether the evidence, considered as a whole and

viewed in the light most favorable to the People, sufficiently

supports the court’s order. People in Interest of R.K.L., 2016 COA

84, ¶ 13. The testimony of the physician seeking to administer

treatment may be sufficient, without more, to satisfy the Medina

test. Id. at ¶ 30.

¶7 Application of the Medina test is a mixed question of fact and

law. People v. Marquardt, 2016 CO 4, ¶ 8. We defer to the district

court’s factual findings if they are supported by the record but

review the court’s legal conclusions de novo. Id. Both the

resolution of testimonial conflicts and the determination of witness

credibility are solely within the province of the fact finder. People in

Interest of Ramsey, 2023 COA 95, ¶ 23. Where the evidence

supports the district court’s findings and conclusions, we may not

3 substitute our judgment for that of the district court. People in

Interest of A.J.L., 243 P.3d 244, 255 (Colo. 2010).

III. The Second Medina Element

¶8 Harden does not contest the sufficiency of the evidence

supporting the first, third, and fourth Medina elements. She

challenges only the second, asserting that insufficient evidence

supports a conclusion that the treatment is necessary to prevent a

significant and likely long-term deterioration in her mental health

condition. We disagree.

¶9 Dr. DeLeon testified that the requested antipsychotic and side

effect medications are necessary to prevent significant and likely

long-term deterioration in Harden’s mental condition. He explained

that, without treatment, Harden’s “prognosis would be poor”

because “untreated psychosis is not a benign or innocent

condition.” Rather, untreated psychosis can contribute to

neuroexcitotoxicity, “which is the over activity within the brain,”

leading to treatment resistance in the future “if it’s left untreated

now.”

¶ 10 Dr. DeLeon further noted that, although Harden had never

previously been hospitalized for psychiatric issues, this was not due

4 to a lack of symptoms or need for treatment. Instead, Harden’s

family reported a multi-year history of psychosis and bizarre

thought processes, as well as unusual behaviors such as throwing

away the family’s pots and pans, shooting her brother with a BB

gun, and deflating the tires of family members’ cars. The family

had avoided psychiatric admission and provided for Harden’s needs

but had “voiced their struggle to do so,” indicating “a history that

support[ed a] previous need for psychiatric admission.”

¶ 11 Implicitly crediting Dr. DeLeon’s testimony, the district court

concluded that, without the requested medications, Harden would

likely experience significant and long-term deterioration of her

mental health condition. The court recognized the chronic nature

of Harden’s mental health condition and noted that her family has

“gone above and beyond to assist her.” But, the court concluded,

schizophrenia is not something that “goes away if we just turn our

back on it and ignore it, and it can continue to get worse and

worse.” The record supports the court’s conclusion.

¶ 12 We acknowledge Harden’s assertion that “Dr. DeLeon’s general

speculation regarding the prognosis of untreated psychosis is by no

means guaranteed to occur,” and that her “history, or lack thereof

5 of,” would seem to indicate that she is “likely to be an exception.”

But the record does not support the assertion that Harden lacks a

mental health history; instead, it shows that she has a long-

standing pattern of untreated psychotic events. Moreover, the

second Medina element does not speak of certainties; it is framed as

a likelihood. And Dr. DeLeon’s expert opinion that, without the

requested medications, Harden would likely suffer significant and

long-term deterioration of her mental health condition is sufficient

to support the court’s conclusion. R.K.L., ¶ 30.

¶ 13 Accordingly, we conclude that the district court’s findings

regarding the second Medina element are supported by clear and

convincing evidence.

IV. Disposition

¶ 14 The order is affirmed.

JUDGE FREYRE and JUDGE PAWAR concur.