Peo in Interest of May

CourtColorado Court of Appeals
DecidedNovember 13, 2025
Docket25CA1634
StatusUnpublished

This text of Peo in Interest of May (Peo in Interest of May) is published on Counsel Stack Legal Research, covering Colorado Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Peo in Interest of May, (Colo. Ct. App. 2025).

Opinion

25CA1634 Peo in Interest of May 11-13-2025

COLORADO COURT OF APPEALS

Court of Appeals No. 25CA1634 Pueblo County District Court No. 25MH30080 Honorable Amiel Markenson, Judge

The People of the State of Colorado,

Petitioner-Appellee,

In the Interest of Harmon Michael May,

Respondent-Appellant.

ORDER AFFIRMED

Division A Opinion by JUDGE HAWTHORNE* Román, C.J., and Martinez*, J., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced November 13, 2025

Cynthia Mitchell, County Attorney, Kate H. Shafer, Special Assistant County Attorney, Pueblo, Colorado, for Petitioner-Appellee

Tezak Law, P.C., Mary Tezak, Florence, Colorado, for Respondent-Appellant

*Sitting by assignment of the Chief Justice under provisions of Colo. Const. art. VI, § 5(3), and § 24-51-1105, C.R.S. 2025. ¶1 Harmon Michael May appeals the district court’s order

authorizing staff at the Colorado Mental Health Hospital in Pueblo

(CMHHIP) to involuntarily administer medication to him. We affirm.

I. Background

¶2 May was committed to CMHHIP for competency restoration in

a criminal case. According to the affidavit of Dr. Hareesh Pillai,

May’s treating physician, May exhibits symptoms of intense

delusions and paranoia, disorganization of thought, impulsivity,

and pressured speech. He is diagnosed with Psychosis, Not

Otherwise Specified.

¶3 CMHHIP began administering psychiatric medications to May

on an emergency basis after an incident where he “began calling

911 repeatedly” and, once he was redirected, “started banging on

the door to his room with both forearms.” Staff observing the

incident reported that May hit the door with such force that they

were concerned he might fracture his arms. The People then

petitioned for a six-month order authorizing the continued

involuntary administration of three medications: Olanzapine (also

known as Zyprexa), Valproic Acid (also known as Depakote), and

Thorazine (also known as Chlorpromazine).

1 ¶4 The district court held an evidentiary hearing on the petition.

Dr. Pillai testified, as did May. At the end of the hearing, the court

found that Dr. Pillai had testified “credibly and persuasively,” and

concluded that the People had proved all four factors set forth in

People v. Medina, 705 P.2d 961 (Colo. 1985). The court issued an

order authorizing CMHHIP staff to administer the requested

medications to May against his will.

II. Discussion

¶5 May concedes that the People met their burden of proving, by

clear and convincing evidence, the first three Medina factors. He

contends, however, that the evidence presented at the hearing was

insufficient to prove the fourth Medina factor. We are not

persuaded.

A. Applicable Law and Standard of Review

¶6 A district court may order the involuntary administration of

medication to a patient only if the People prove, by clear and

convincing evidence, each of the four factors outlined in Medina:

(1) the patient is incompetent to effectively participate in the treatment decision;

(2) treatment by antipsychotic medication is necessary to prevent a significant and likely

2 long-term deterioration in the patient’s mental condition or to prevent the likelihood of the patient’s causing serious harm to himself or others in the institution;

(3) a less intrusive treatment alternative is not available; and

(4) the patient’s need for treatment by antipsychotic medication is sufficiently compelling to override any bona fide and legitimate interest of the patient in refusing treatment.

Id. at 963-64. A psychiatrist’s testimony may suffice to meet this

burden. See People v. Pflugbeil, 834 P.2d 843, 847 (Colo. App.

1992).

¶7 When a patient challenges the sufficiency of the evidence

supporting an involuntary medication order, we review the district

court’s legal conclusions de novo but defer to its findings of fact if

they have record support. People v. Marquardt, 2016 CO 4, ¶ 8. We

view the evidence as a whole and in the light most favorable to the

People to determine if it is sufficient to support the district court’s

order. People in Interest of R.K.L., 2016 COA 84, ¶ 13. If it is, we

may not substitute our judgment for that of the district court. See

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

3 B. Fourth Medina Factor

¶8 May contests the district court’s findings regarding only the

fourth Medina factor that requires a court to first determine

“whether the patient’s refusal is bona fide and legitimate.” Medina,

705 P.2d at 974. If so, the court must determine “whether the

prognosis without treatment is so unfavorable that the patient’s

personal preference must yield to the legitimate interests of the

state in preserving the life and health of the patient placed in its

charge and in protecting the safety of those in the institution.” Id.

¶9 The district court found that May did not have a bona fide and

legitimate interest in refusing treatment based on his religious

beliefs. However, it noted that May also testified that he did not like

receiving shots, which the court found legitimate because of the

intrusiveness, pain, and bruising shots could cause. Nonetheless,

the court found that May’s prognosis, without treatment, is so

unfavorable that his personal preference must yield to the

legitimate interest of the State in preserving his life and health

while he is placed in the charge of CMHHIP. The record supports

these findings.

4 ¶ 10 Dr. Pillai testified that without the requested medications May

“had odd delusions and paranoia” including comments that he was

“being killed every night in jail and being reincarnated every day.”

And Dr. Pillai described May’s “bizarre” behavior including the

incident the precipitated emergency medications during which

CMHHIP staff were concerned about May breaking his arms when

he repeatedly banged them against a door. May admitted to

banging his arms repeatedly — although he claimed it was against

a brick wall rather than a door. May also agreed that banging his

arms in such a way was “not smart to do,” and that he could have

injured himself.

¶ 11 May asserts that the district court specifically found that he

was not a danger to others in the institution and, accordingly, the

State’s interest was “diminished considerably” and that his religious

reasons for preferring a “drug-free lifestyle” outweigh the State’s

interest in forcibly medicating him.

¶ 12 First, we note that the court found no bona fide reason based

on May’s religious beliefs because he testified that he does not

believe in one religion. Indeed, May never connected his desire to

live a “drug-free lifestyle” to any particular religion or religious

5 belief. Nonetheless, the court found May had a legitimate reason to

refuse medication by injection because he did not like shots.

Moreover, the court found that even if it made the “wrong” finding

about his legitimate interests, the prognosis without treatment is so

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Related

People v. Medina
705 P.2d 961 (Supreme Court of Colorado, 1985)
People v. Pflugbeil
834 P.2d 843 (Colorado Court of Appeals, 1992)
People v. Marquardt
2016 CO 4 (Supreme Court of Colorado, 2016)
People ex rel. R.K.L
2016 COA 84 (Colorado Court of Appeals, 2016)

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