State

Court of Appeals of Texas·Decided December 9, 2011·No. 06-11-00117-CV·Published

Opinion

                                                         In The

                                                Court of Appeals

                        Sixth Appellate District of Texas at Texarkana

                                                ______________________________

                                                             No. 06-11-00117-CV

              THE STATE OF TEXAS FOR THE BEST INTEREST

                                    AND PROTECTION OF S.W.

                                          On Appeal from the County Court at Law #2

                                                              Hunt County, Texas

                                                          Trial Court No. M-10152

                                          Before Morriss, C.J., Carter and Moseley, JJ.

                                                    Opinion by Chief Justice Morriss


                                                                   O P I N I O N

            On September 29, 2011, S.W., a twenty-five-year-old female, appeared in an emergency room in Hunt County complaining of suicidal thoughts and acting aggressively toward emergency-room staff.[1]  Diagnosed with schizoaffective disorder and as bipolar, S.W. has been involuntarily committed to inpatient mental health treatment.[2]  Because we find no evidence in the record of a recent overt act or continuing pattern of behavior that tends to confirm the likelihood of serious harm to S.W. or a substantial deterioration of S.W.’s ability to function independently to provide for her basic needs, we reverse the judgment of the trial court.

            At the October 17, 2011, hearing on the State’s application for court-ordered extended mental health services,[3] the trial court found that S.W. was mentally ill and that, as a result of her mental illness, she was likely to cause serious harm to herself.  The trial court further found that S.W. “will, if not treated, continue to suffer severe and abnormal mental, emotional or physical distress and will continue to experience deterioration of the ability to function independently and is unable to make a rational and informed decision as to whether or not to submit to treatment.” 

            A trial court may order the temporary inpatient mental health services of a proposed patient only if the fact-finder concludes, from clear and convincing evidence, that the proposed patient is mentally ill and also satisfies at least one of the subparagraphs (A), (B), or (C) of Section 574.034(a)(2) of the Texas Health and Safety Code, requiring that the proposed patient, due to the mental illness:

            (A)       is likely to cause serious harm to himself;

            (B)       is likely to cause serious harm to others; or

            (C)       is:

                        (i)         suffering severe and abnormal mental, emotional, or physical distress;

                                                (ii)        experiencing substantial mental or physical deterioration of the proposed patient’s ability to function independently, which is exhibited by the proposed patient’s inability, except for reasons of indigence, to provide for the proposed patient’s basic needs, including food, clothing, health, or safety; and

                                                (iii)       unable to make a rational and informed decision as to whether or not to submit to treatment.

Tex. Health & Safety Code Ann. § 574.034(a)(2) (West 2010).  If the trial court finds that the proposed patient meets the prescribed commitment criteria, it must then specify which criterion forms the basis of the decision.  Tex. Health & Safety Code Ann. § 574.034(c) (West 2010).  Here, mental illness is not disputed, and there is no claim S.W. is a threat to others.  Rather, S.W. contends the evidence is legally insufficient to establish, by clear and convincing evidence, a recent overt act or a continuing pattern of behavior that tends to confirm (1) that S.W. was likely to cause serious harm to herself or (2) S.W.’s distress and the deterioration of her ability to function.  See Tex. Health & Safety Code Ann. § 574.034(a)(2)(A), (C).

            “[A] State cannot constitutionally confine without more a nondangerous individual who is capable of surviving safely in freedom by himself or with the help of willing and responsible family members or friends.”  O’Connor v. Donaldson, 422 U.S. 563, 576 (1975).  The requirements for an involuntary commitment are strict because an involuntary commitment is a drastic measure.  In re Breeden, 4 S.W.3d 782, 789 (Tex. App.—San Antonio 1999, no pet.).  The evidentiary standards for involuntary commitment are high.  State ex rel. E.E., 224 S.W.3d 791, 794 (Tex. App.—Texarkana 2007, no pet.); Harris v. State, 615 S.W.2d 330, 333 (Tex. Civ. App.—Fort Worth 1981, writ ref’d n.r.e.).  The State has the burden of establishing by clear and convincing evidence that the proposed patient meets at least one of the additional criteria listed in Section 574.034(a)(2) of the Texas Health and Safety Code.  State ex rel. L.H., 183 S.W.3d 905, 909 (Tex. App.—Texarkana 2006, no pet.). 

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