The State of Texas for the Best Interest and Protection of A. D. S. v. the State of Texas

CourtCourt of Appeals of Texas
DecidedJuly 31, 2023
Docket12-23-00143-CV
StatusPublished

This text of The State of Texas for the Best Interest and Protection of A. D. S. v. the State of Texas (The State of Texas for the Best Interest and Protection of A. D. S. v. the State of Texas) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
The State of Texas for the Best Interest and Protection of A. D. S. v. the State of Texas, (Tex. Ct. App. 2023).

Opinion

NO. 12-23-00143-CV

IN THE COURT OF APPEALS

TWELFTH COURT OF APPEALS DISTRICT

TYLER, TEXAS

THE STATE OF TEXAS FOR THE § APPEAL FROM THE

BEST INTEREST AND PROTECTION § COUNTY COURT AT LAW

OF A.D.S. § CHEROKEE COUNTY, TEXAS

MEMORANDUM OPINION A.D.S. appeals from an order authorizing the administration of psychoactive medication. In his sole issue, A.D.S. challenges the legal and factual sufficiency of the evidence to support the trial court’s order. We affirm.

BACKGROUND A.D.S. was found incompetent to stand trial and committed to Rusk State Hospital for examination and treatment with the specific objective of attaining competency. A.D.S. refused to take medication prescribed for his condition and denied needing medication. On May 17, 2023, Dr. Jill K. Pontius signed an application to order the administration of psychoactive medication. After conducting a hearing, the trial court signed an order authorizing the administration of psychoactive medication. In its order, the trial court stated that the allegations in the application are supported by clear and convincing evidence. The trial court concluded that A.D.S. lacks the capacity to make a decision regarding the administration of psychoactive medication and that treatment with the proposed medications is in his best interest. This appeal followed.

SUFFICIENCY OF THE EVIDENCE In his sole issue, A.D.S. argues that the evidence is legally and factually insufficient to support the trial court’s order authorizing administration of psychoactive medication. Specifically, A.D.S. contends the evidence failed to establish that the proposed medications were in his best interest. Standard of Review Texas law requires that orders authorizing administration of psychoactive medication be supported by clear and convincing evidence. TEX. HEALTH & SAFETY CODE ANN. § 574.106(a-1) (West 2017). “Clear and convincing evidence” means the measure or degree of proof that will produce in the mind of the trier of fact a firm belief or conviction as to the truth of the allegations sought to be established. State v. Addington, 588 S.W.2d 569, 570 (Tex. 1979). Although the proof must weigh more heavily than merely the greater weight of the credible evidence, the evidence need not be unequivocal or undisputed. Id. In conducting a legal sufficiency review when the burden of proof is clear and convincing evidence, we look at all the evidence in the light most favorable to the finding to determine whether a reasonable trier of fact could have formed a firm belief or conviction that its findings were true. In re J.F.C., 96 S.W.3d 256, 266 (Tex. 2002). We assume that the factfinder settled disputed facts in favor of its finding if a reasonable factfinder could do so and disregard all evidence that a reasonable factfinder could have disbelieved or found incredible. Id. When reviewing factual sufficiency, we must give due consideration to evidence that the factfinder could reasonably have found to be clear and convincing and then determine whether, based on the entire record, a factfinder could reasonably form a firm conviction or belief that the allegations in the petition were proven. Id. We must consider whether the disputed evidence is such that a reasonable factfinder could not have reconciled that disputed evidence in favor of its finding. Id. If the disputed evidence is so significant that a factfinder could not reasonably have formed a firm belief in the finding, the evidence is factually insufficient. Id. The factfinder is the sole arbiter of the credibility and demeanor of witnesses. In re H.R.M., 209 S.W.3d 105, 109 (Tex. 2006). Applicable Law A trial court may issue an order authorizing the administration of one or more classes of psychoactive medications to a patient who is under a court order to receive inpatient mental health services. TEX. HEALTH & SAFETY CODE ANN. § 574.106(a) (West 2017). The court may issue an order if it finds by clear and convincing evidence after the hearing that (1) the patient lacks the capacity to make a decision regarding the administration of the proposed medication, and (2) treatment with the proposed medication is in the patient’s best interest. Id. § 574.106 (a-1).

2 “Capacity” means a patient’s ability to (1) understand the nature and consequences of a proposed treatment, including the benefits, risks, and alternatives to the proposed treatment, and (2) make a decision whether to undergo the proposed treatment. Id. § 574.101(1) (West 2017). In making a finding that treatment with the proposed medication is in the patient’s best interest, the trial court shall consider (1) the patient’s expressed preferences regarding treatment with psychoactive medication, (2) the patient’s religious beliefs, (3) the risks and benefits, from the patient’s perspective, of taking psychoactive medication, (4) the consequences to the patient if the psychoactive medication is not administered, (5) the patient’s prognosis if he is treated with psychoactive medication, (6) alternative, less intrusive treatments that are likely to produce the same results as treatment with psychoactive medication, and (7) less intrusive treatments likely to secure the patient’s agreement to take the psychoactive medication. Id. § 574.106(b). Analysis Dr. Pontius’s application states that A.D.S. is subject to an order for court-ordered inpatient mental health services due to his incompetency to stand trial. According to the application, Dr. Pontius diagnosed A.D.S. with schizoaffective disorder, bipolar type; cocaine use disorder; opioid use disorder; and HIV infection. Additionally, the application states that (1) A.D.S. refuses to take the medication voluntarily and (2) A.D.S. lacks the capacity to make a decision regarding administration of psychoactive medication because, although A.D.S. initially agreed to take medication and signed consent forms, he “refused monitoring lab draws,” “declined several doses of medications,” and “is unable to engage in a rational discussion of his need for medications or the risks [versus] benefits of taking them daily.” Dr. Pontius also stated in the application that if treated with psychoactive medication, A.D.S. will have an “[i]mproved prognosis with possibility of competency restoration.” The application also stated that if the medications were not administered, A.D.S. would suffer psychotic deterioration and would need prolonged hospitalization. Moreover, Dr. Pontius stated in the application that she considered alternatives to psychoactive medication, but determined that medical alternatives would not be as effective as administration of psychoactive medication. Furthermore, Dr. Pontius’s application indicated that the benefits of psychoactive medication outweigh the risks, and that treatment with the proposed medication is in A.D.S.’s best interest. At the hearing on the application, Dr. Pontius testified that she is A.D.S.’s treating physician, and when asked if she swears that the statements in the application for administration

3 of psychoactive medication are true and correct, she responded affirmatively. Dr. Pontius explained that A.D.S. suffers from schizoaffective disorder, bipolar type; cocaine use disorder; opioid use disorder; and HIV infection. According to Dr. Pontius, A.D.S. “initially agreed to take the medication and signed consent forms for it, then he refused monitoring lab draws and has declined . . . both of the medications.” Dr. Pontius indicated that A.D.S.

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Related

State v. Addington
588 S.W.2d 569 (Texas Supreme Court, 1979)
In the Interest of J.F.C.
96 S.W.3d 256 (Texas Supreme Court, 2002)
In the Interest of H.R.M.
209 S.W.3d 105 (Texas Supreme Court, 2006)

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The State of Texas for the Best Interest and Protection of A. D. S. v. the State of Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/the-state-of-texas-for-the-best-interest-and-protection-of-a-d-s-v-the-texapp-2023.