25CA0576 Peo in Interest of Snyder 06-12-2025
COLORADO COURT OF APPEALS
Court of Appeals No. 25CA0576 Arapahoe County District Court No. 25MH108 Honorable H. Clay Hurst, Judge
The People of the State of Colorado,
Petitioner-Appellee,
In the Interest of Patrick Snyder,
Respondent-Appellant.
ORDER AFFIRMED
Division V Opinion by JUDGE JOHNSON Welling and Grove, JJ., concur
NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced June 12, 2025
Ron Carl, County Attorney, Meghan Rubincam, Senior Assistant County Attorney, Aurora, Colorado, for Petitioner-Appellee
Tezak Law P.C., Mary Tezak, Florence, Colorado, for Respondent-Appellant ¶1 Patrick Snyder (Snyder) appeals the district court’s order
certifying him for long-term care and treatment. He contests the
sufficiency of the evidence supporting the order. We affirm.
I. Background
¶2 Snyder has been a client of Aurora Mental Health & Recovery
(AMHR) since 2020. He has a longstanding history of psychiatric
hospitalizations and difficulty following through with treatment
recommendations, including maintaining compliance with
prescribed antidepressant, mood-stabilizing, and antipsychotic
medications.
¶3 Snyder was originally certified for short-term treatment at
AMHR. On February 26, 2025, his treatment provider, Dr. Kris
Olson (Dr. Olson), filed a petition for long-term certification on an
outpatient basis. The petition alleged that Snyder is a danger to
others and is gravely disabled. Although Snyder had accepted
voluntary treatment, the petition alleged that reasonable grounds
existed to believe that he would not remain in a voluntary treatment
program.
1 ¶4 The district court held a hearing on the matter and entered an
order confirming the long-term certification. As relevant here, the
court found by clear and convincing evidence that (1) Snyder is
gravely disabled as a result of his mental health disorder and (2)
reasonable grounds exist to believe he will not remain in treatment
voluntarily, notwithstanding his previous acceptance of treatment.
The court rejected the allegation that Snyder is a danger to others.
II. Standard of Review and Applicable Law
¶5 In reviewing the sufficiency of the evidence in a mental health
proceeding, we determine whether the evidence, viewed as a whole
and in the light most favorable to the petitioning party, is sufficient
to support the court’s order. People in Interest of R.K.L., 2016 COA
84, ¶ 13. We defer to the court’s factual findings if there is evidence
supporting them, but we review the court’s legal conclusions de
novo. People in Interest of Strodtman, 293 P.3d 123, 131 (Colo. App.
2011).
¶6 Under specified circumstances, section 27-65-110, C.R.S.
2024, permits a professional in charge of a patient’s short-term
2 certification and treatment to file a petition to certify the patient for
long-term care and treatment. See § 27-65-110(1); see generally
Perreira v. State, 768 P.2d 1198 (Colo. 1989) (providing an overview
of the certification process). As relevant here, to authorize long-
term certification for mental health treatment, a court must find by
clear and convincing evidence that the patient (1) has a mental
health disorder and, as a result, is gravely disabled or a danger to
himself or others; and (2) has been advised of the availability of, but
has not accepted, voluntary treatment. §§ 27-65-110(1)(a)-(b), 27-
65-113(1), C.R.S. 2024. Clear and convincing evidence is “evidence
that is highly probable and free from serious or substantial doubt.”
Destination Maternity v. Burren, 2020 CO 41, ¶ 10 (citation omitted).
If reasonable grounds exist to believe that the patient will not
remain in a voluntary treatment program, however, the patient’s
acceptance of voluntary treatment does not preclude a long-term
certification order. § 27-65-110(1)(b).
3 III. Analysis
¶7 Snyder contends that insufficient evidence supports the
district court’s conclusion that he is gravely disabled. He further
contends that the district court erred by finding that reasonable
grounds exist to believe that he will not remain in treatment
voluntarily. We reject these contentions.
A. Gravely Disabled
¶8 “Gravely disabled” means that, due to a mental health
disorder, a person is incapable of making informed decisions about
or providing for his essential needs without significant supervision
and assistance from other people. § 27-65-102(17), C.R.S. 2024.
As a result, such a person “is at risk of substantial bodily harm,
dangerous worsening of any concomitant serious physical illness,
significant psychiatric deterioration, or mismanagement of the
person’s essential needs that could result in substantial bodily
harm.” Id. A person is gravely disabled if he is “unable to take care
of basic personal needs.” People v. Taylor, 618 P.2d 1127, 1134
(Colo. 1980). Basic personal needs means “those fundamental
necessities of human existence, such as food, shelter, clothing, and 4 medical care, which an individual must obtain and maintain in
order to live safely.” Id.
¶9 Snyder asserts that the evidence does not support a finding
that he is gravely disabled because Dr. Olson testified that, “at one
time,” Snyder was “capable of making decisions about or providing
for his essential needs without significant supervision from others”
and was able to “make his own meals and those sorts of things.”
But Dr. Olson testified that his ability to care for himself was “in the
past when he was . . . better medicated,” and that he is not
presently able to “effectively participate in treatment planning in his
psychiatric care” due to “his lack of understanding or acceptance
of . . . having a mental illness.” And she testified that Snyder
currently resides in an assisted living facility, to which a team at
AMHR helped him get admitted and without which he would have
“nowhere to go.”
¶ 10 Dr. Olson noted that the staff at the assisted living facility
provides medication management and meals, and the facility is a
safe place to live. And she testified that Snyder is not currently
5 capable of “making informed decisions about his mental health
treatment and [the] medications that he needs.” Finally, she stated
that, if his certification was terminated, his prognosis would be poor
because she would expect that he would cease taking his
medications, his psychotic symptoms would increase, and his mood
and instability “would be worse.” As result, her expert opinion was
that Snyder is gravely disabled as a result of his mental illness.
¶ 11 Under these circumstances, we perceive no error in the district
court’s determination that Snyder is gravely disabled. The record
supports the determination that Snyder is presently reliant on
others to make certain informed decisions and for certain essential
needs, and that he is at risk for serious deterioration without “all
the supports that he’s relying on right now.”
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25CA0576 Peo in Interest of Snyder 06-12-2025
COLORADO COURT OF APPEALS
Court of Appeals No. 25CA0576 Arapahoe County District Court No. 25MH108 Honorable H. Clay Hurst, Judge
The People of the State of Colorado,
Petitioner-Appellee,
In the Interest of Patrick Snyder,
Respondent-Appellant.
ORDER AFFIRMED
Division V Opinion by JUDGE JOHNSON Welling and Grove, JJ., concur
NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced June 12, 2025
Ron Carl, County Attorney, Meghan Rubincam, Senior Assistant County Attorney, Aurora, Colorado, for Petitioner-Appellee
Tezak Law P.C., Mary Tezak, Florence, Colorado, for Respondent-Appellant ¶1 Patrick Snyder (Snyder) appeals the district court’s order
certifying him for long-term care and treatment. He contests the
sufficiency of the evidence supporting the order. We affirm.
I. Background
¶2 Snyder has been a client of Aurora Mental Health & Recovery
(AMHR) since 2020. He has a longstanding history of psychiatric
hospitalizations and difficulty following through with treatment
recommendations, including maintaining compliance with
prescribed antidepressant, mood-stabilizing, and antipsychotic
medications.
¶3 Snyder was originally certified for short-term treatment at
AMHR. On February 26, 2025, his treatment provider, Dr. Kris
Olson (Dr. Olson), filed a petition for long-term certification on an
outpatient basis. The petition alleged that Snyder is a danger to
others and is gravely disabled. Although Snyder had accepted
voluntary treatment, the petition alleged that reasonable grounds
existed to believe that he would not remain in a voluntary treatment
program.
1 ¶4 The district court held a hearing on the matter and entered an
order confirming the long-term certification. As relevant here, the
court found by clear and convincing evidence that (1) Snyder is
gravely disabled as a result of his mental health disorder and (2)
reasonable grounds exist to believe he will not remain in treatment
voluntarily, notwithstanding his previous acceptance of treatment.
The court rejected the allegation that Snyder is a danger to others.
II. Standard of Review and Applicable Law
¶5 In reviewing the sufficiency of the evidence in a mental health
proceeding, we determine whether the evidence, viewed as a whole
and in the light most favorable to the petitioning party, is sufficient
to support the court’s order. People in Interest of R.K.L., 2016 COA
84, ¶ 13. We defer to the court’s factual findings if there is evidence
supporting them, but we review the court’s legal conclusions de
novo. People in Interest of Strodtman, 293 P.3d 123, 131 (Colo. App.
2011).
¶6 Under specified circumstances, section 27-65-110, C.R.S.
2024, permits a professional in charge of a patient’s short-term
2 certification and treatment to file a petition to certify the patient for
long-term care and treatment. See § 27-65-110(1); see generally
Perreira v. State, 768 P.2d 1198 (Colo. 1989) (providing an overview
of the certification process). As relevant here, to authorize long-
term certification for mental health treatment, a court must find by
clear and convincing evidence that the patient (1) has a mental
health disorder and, as a result, is gravely disabled or a danger to
himself or others; and (2) has been advised of the availability of, but
has not accepted, voluntary treatment. §§ 27-65-110(1)(a)-(b), 27-
65-113(1), C.R.S. 2024. Clear and convincing evidence is “evidence
that is highly probable and free from serious or substantial doubt.”
Destination Maternity v. Burren, 2020 CO 41, ¶ 10 (citation omitted).
If reasonable grounds exist to believe that the patient will not
remain in a voluntary treatment program, however, the patient’s
acceptance of voluntary treatment does not preclude a long-term
certification order. § 27-65-110(1)(b).
3 III. Analysis
¶7 Snyder contends that insufficient evidence supports the
district court’s conclusion that he is gravely disabled. He further
contends that the district court erred by finding that reasonable
grounds exist to believe that he will not remain in treatment
voluntarily. We reject these contentions.
A. Gravely Disabled
¶8 “Gravely disabled” means that, due to a mental health
disorder, a person is incapable of making informed decisions about
or providing for his essential needs without significant supervision
and assistance from other people. § 27-65-102(17), C.R.S. 2024.
As a result, such a person “is at risk of substantial bodily harm,
dangerous worsening of any concomitant serious physical illness,
significant psychiatric deterioration, or mismanagement of the
person’s essential needs that could result in substantial bodily
harm.” Id. A person is gravely disabled if he is “unable to take care
of basic personal needs.” People v. Taylor, 618 P.2d 1127, 1134
(Colo. 1980). Basic personal needs means “those fundamental
necessities of human existence, such as food, shelter, clothing, and 4 medical care, which an individual must obtain and maintain in
order to live safely.” Id.
¶9 Snyder asserts that the evidence does not support a finding
that he is gravely disabled because Dr. Olson testified that, “at one
time,” Snyder was “capable of making decisions about or providing
for his essential needs without significant supervision from others”
and was able to “make his own meals and those sorts of things.”
But Dr. Olson testified that his ability to care for himself was “in the
past when he was . . . better medicated,” and that he is not
presently able to “effectively participate in treatment planning in his
psychiatric care” due to “his lack of understanding or acceptance
of . . . having a mental illness.” And she testified that Snyder
currently resides in an assisted living facility, to which a team at
AMHR helped him get admitted and without which he would have
“nowhere to go.”
¶ 10 Dr. Olson noted that the staff at the assisted living facility
provides medication management and meals, and the facility is a
safe place to live. And she testified that Snyder is not currently
5 capable of “making informed decisions about his mental health
treatment and [the] medications that he needs.” Finally, she stated
that, if his certification was terminated, his prognosis would be poor
because she would expect that he would cease taking his
medications, his psychotic symptoms would increase, and his mood
and instability “would be worse.” As result, her expert opinion was
that Snyder is gravely disabled as a result of his mental illness.
¶ 11 Under these circumstances, we perceive no error in the district
court’s determination that Snyder is gravely disabled. The record
supports the determination that Snyder is presently reliant on
others to make certain informed decisions and for certain essential
needs, and that he is at risk for serious deterioration without “all
the supports that he’s relying on right now.”
¶ 12 We are not persuaded otherwise by Snyder’s reliance on his
own recognition that he “[p]robably” has a mental health disorder
and accepts the fact that he needs to be treated but would like to
choose a different provider. These facts do not undermine Dr.
Olson’s testimony, which the district court found “most credible.”
6 B. Reasonable Grounds
¶ 13 Snyder also asserts that the record does not support the
court’s finding that reasonable grounds exist to believe that he will
not remain in a voluntary treatment program. He relies on Dr.
Olson’s testimony that he resides at the assisted living facility
voluntarily, as well as his testimony that he does not contest his
need for treatment. Be that as it may, Dr. Olson’s certification
statement — on which the court relied — represented that such
reasonable grounds existed. Dr. Olson testified that although
Snyder had expressed a desire to find a different care provider, she
was not confident that “he would stay in care with another
provider,” in part because of his history of ceasing medications, and
in part because he had expressed a desire to leave the state.
¶ 14 Thus, we conclude that sufficient evidence supports the
court’s determination.
IV. Conclusion
¶ 15 The order is affirmed.
JUDGE WELLING and JUDGE GROVE concur.