DORETTA FELTON
v.
STATE OF FLORIDA

Fla. 1st DCA | 2021-10-13
No. 20-3417
Jay, J., M.K. Thomas, J., Long, J.
Florida District Court of Appeal, First District (2021)

AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.

Synopsis

Ms. Felton appeals a trial court order authorizing involuntary psychiatric medication. The court affirmed, holding that the physician's testimony established competent, substantial evidence supporting the essential nature of the treatment under Florida's statutory framework for treating individuals found not guilty by reason of insanity.


Holding

The appellate court affirmed the trial court's order, holding that the physician's testimony constituted competent, substantial evidence supporting all statutory requirements for involuntary treatment authorization, and that the trial court properly exercised its prerogative to resolve credibility disputes between the physician's and Ms. Felton's testimony.


Headnotes

[1] Appellate courts have jurisdiction to review final orders of trial courts.

[2] Orders authorizing involuntary medical treatment under section 916.107 are reviewed for competent, substantial evidence.

Previewing 2 of 5 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.

Join FLexlaw to unlock all legal intelligence

Key Quotes

“We review orders authorizing treatment under section 916.107 for competent, substantial evidence.”

Establishes the standard of review applicable to involuntary treatment orders under Florida law.

Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.

Join FLexlaw to unlock all legal intelligence

Facts & Procedural History

Ms. Felton was found not guilty by reason of insanity on two charges of child neglect and is hospitalized at Florida State Hospital. She has been diag…

The full statement of facts, procedural history, and disposition for this case are member content.

Join FLexlaw to unlock all legal intelligence

© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.


Opinion of the Court
Long

PER CURIAM.

Ms. Felton appeals the trial court’s order authorizing involuntary medical treatment. Ms. Felton was found not guilty by reason of insanity on two charges of child neglect and is a patient at Florida State Hospital. Ms. Felton has been diagnosed with schizoaffective disorder and her physician believed increased dosage of her medication would reduce her symptomatic and disruptive behavior. The Department of Children and Families petitioned the trial court pursuant to section 916.107(3) to authorize nonemergency but essential treatment. After a hearing where testimony from both Ms. Felton’s physician and Ms. Felton was heard, the trial court made the necessary findings and ordered treatment for 90 days.

We have jurisdiction to review final orders of trial courts. Art. V, § 4(b)(1), Fla. Const. We review orders authorizing treatment under section 916.107 for competent, substantial evidence. Dinardo v. State, 742 So. 2d 287, 289 (Fla. 1st DCA 1998). The testimony of Ms. Felton’s physician meets this standard. The physician testified that Ms. Felton is mentally ill, that the treatment is essential to her care, and that the treatment is not experimental and does not present an unreasonable risk of serious, hazardous, or irreversible side effects. § 916.107(3)(a)3, Fla. Stat. (2020). Ms. Felton’s argument that her testimony contradicted her physician’s is unpersuasive given that it is the prerogative of the trial judge to resolve credibility disputes. AFFIRMED. JAY, M.K. THOMAS, and LONG, JJ., concur. _____________________________


Cases With Similar Vibessemantic neighbors from the corpus


Citator

Authorities Cited

Full citator, related cases, and AI research tools

Open in FLexlaw