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In re I.E.J.

Court of Appeal of Iowa

July 10, 2013

IN RE I.E.J., Alleged to Be Seriously Mentally Impaired, I.E.J., Respondent-Appellant.

Appeal from the Iowa District Court for Johnson County, Stephen B. Jackson Jr., Judge.

I.E.J. appeals from a district court order requiring hospitalization due to serious mental impairment.

Willie E. Townsend, Coralville, for appellant.

Thomas J. Miller, Attorney General, Gretchen Witte Kraemer, Assistant Attorney General, Janet M. Lyness, County Attorney, and Jude Pannell, Assistant County Attorney, for State.

Considered by Doyle, P.J., and Danilson and Mullins, JJ.

DOYLE, P.J.

I.E.J. appeals the district court's order finding him to be seriously mentally impaired. We affirm.

I. Background Facts and Proceedings.

I.E.J. is currently serving a life sentence in the Iowa prison system. I.E.J. was committed to a mental health institute for evaluation after cutting another inmate's neck with a razor. I.E.J. was subsequently diagnosed as having a persecutory type delusional disorder, a mental illness under the DSM IV. I.E.J.'s commitment was ordered to continue fulltime in June 2012.

In August 2012, a periodic report concerning I.E.J.'s commitment was filed pursuant to Iowa Code section 229.15(2) (2011). In the report, I.E.J.'s treating physician opined that I.E.J.'s condition remained unchanged. Additionally, he concluded I.E.J. was seriously mentally impaired and in need of full-time custody and care, but I.E.J. was unlikely to benefit from treatment in a hospital. The physician recommended I.E.J.'s commitment be continued.

I.E.J. appealed, challenging his confinement as a seriously mentally impaired individual pursuant to Iowa Code section 229.37.[1] A hearing on I.E.J.'s review request was held, and I.E.J. testified, along with I.E.J.'s treating physician and a correctional counselor. Thereafter, the district court found, because of his impairment, I.E.J. was incapable of making responsible decisions concerning his hospitalization and treatment. The court further found the State presented clear and convincing evidence that I.E.J. was likely to physically injure himself or others if allowed to remain at liberty.

I.E.J. now appeals.[2] I.E.J. does not contest his physician's opinion that he suffers from a mental illness. Rather, he challenges the sufficiency of the evidence that he lacks sufficient judgment to make reasonable decisions with respect to his hospitalization or treatment and that he was likely to physically injure himself or others if allowed to remain at liberty. Additionally, I.E.J. contends the Iowa Medical Classification Center ("IMCC") "is using Iowa Code [chapter] 229 as a tool of convenience for the application of medication rather than as the tool the legislature intended."

II. Scope and Standards of Review.

We review sufficiency of the evidence challenges in involuntary commitment appeals for errors at law. In re B.B., 826 N.W.2d 425, 428 (Iowa 2013). The district court's findings of fact are binding on us if supported by substantial evidence. In re J.P., 574 N.W.2d 340, 342 (Iowa 1998). "Evidence is substantial if a reasonable trier of fact could conclude the findings were established by clear and convincing evidence." Id. Clear and convincing evidence "means that there must be no serious or substantial doubt about the correctness of a particular conclusion drawn from the evidence." B.B., 826 N.W.2d at 428. It has been uniformly held that the trial court's findings in a habeas ...


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