Involuntary mental health treatment; Person requiring treatment; MCL 330.1401(1)(a)-(c)

The court concluded “that the probate court did not clearly err when it found respondent was a person requiring treatment under MCL 330.1401(1)(a) through (c). [Thus], the probate court did not abuse its discretion when it entered the second order for involuntary mental health treatment.” First, her “treating psychiatrist testified that respondent suffered from schizophrenia and described schizophrenia as a thought disorder. Another psychiatrist also opined that respondent suffered from schizophrenia.” Second, the record showed that her “mental illness impaired her capacity to recognize reality.” The record also demonstrated that her “mental illness impaired her behavior, as some of her hallucinations involved commands to attack hospital staff.” Further, the record indicated that her “mental illness impaired her judgment by causing her to believe that she could heal herself and that she did not have a mental illness. That respondent was homeless before she was hospitalized also suggests that her illness rendered her unable to cope with the demands of normal life. The foregoing strongly demonstrates that the probate court did not clearly err when it found that respondent had a mental illness.” Also, the probate court “did not clearly err when it found that [she] was a person in need of treatment under MCL 330.1401(1)(a).” The court found that while none of the attacks appeared “to have resulted in serious harm, respondent’s willingness to listen to voices in her head allegedly instructing her to attack others demonstrates that the probate court did not clearly err by finding there was a reasonable expectation that she could seriously injure herself or others in the near future. Further, another psychiatrist opined that respondent was dangerous because she was assaultive and suffered from hallucinations. These facts were sufficient for the probate court to form a firm conviction that [she] was a person needing treatment under MCL 330.1401(1)(a). Additionally, the probate court did not clearly err by finding that [she] was a person in need of treatment under MCL 330.1401(1)(b). When she was on her own, respondent did not provide herself with food or shelter.” That she “wanted to set up a tent near a hospital demonstrated that she did not have a good grasp on how to provide for her basic needs. Further, the fact that respondent’s delusions controlled her behavior suggested that she was unable to address her basic needs.” Additionally, the court noted that “both psychiatrists opined that respondent’s mental illness rendered her unable to care for her own basic needs. These facts were sufficient for the probate court to form a firm conviction that [she] was a person needing treatment under MCL 330.1401(1)(b).” Finally, the court found that “the probate court did not clearly err by finding that respondent was a person in need of treatment under MCL 330.1401(1)(c). Respondent refused to recognize that she had a mental illness and testified that she did not have a mental illness.” Though she “ultimately agreed that she would take her medication if she was discharged, this statement was undermined by her unwillingness to take her medication while under direct medical supervision, as well as her belief that she could heal herself.” Affirmed.