BARBARA SINGLETARY, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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.
Barbara Singletary challenges her involuntary psychiatric commitment to Northeast Florida State Hospital. The court reverses her commitment, finding the state failed to establish by clear and convincing evidence that she met the statutory criteria for involuntary placement under Florida law.
The court reversed the involuntary commitment order, finding the state failed to meet its burden of proving by clear and convincing evidence that less restrictive alternatives were unavailable and that Singletary posed a real and present threat of substantial harm. The mere existence of mental illness is insufficient for commitment, and the mother's offer of supervised care in a new environment constituted a viable alternative the state did not adequately rebut.
[1] Involuntary commitment requires proof by clear and convincing evidence that a person is mentally ill and, because of that illness, is unable to survive alone or with help…
[2] A mere need for treatment or medication does not, in itself, justify involuntary commitment.
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“The state has the burden to establish the criteria for involuntary placement set out in section 394.467, Florida Statutes (1999), by clear and convincing evidence.”
Establishes the standard of proof required for involuntary psychiatric commitment in Florida.
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceSingletary suffered from mental illness manifesting primarily in religious delusions. Her symptoms could be controlled by medication, but she had a te…
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.
Explore caselaw by topic → Browse Involuntary Commitment Criteria cases and more on FLexlaw
PER CURIAM.
Barbara Singletary appeals her involuntary placement in the Northeast Florida State Hospital. She contends that the state failed to present clear and convincing evidence that she met the criteria for involuntary placement. We agree and reverse.
The state has the burden to establish the criteria for involuntary placement set out in section 394.467, Florida Statutes (1999), by clear and convincing evidence. See In re Beverly, 342 So. 2d 481 (Fla.1977); Archer v. State, 681 So. 2d 296 (Fla. 1st DCA 1996); Jones v. State, 611 So. 2d 577 (Fla. 1st DCA 1992); Braden v. State, 575 So. 2d 756 (Fla. 1st DCA 1991); Welk v. State, 542 So. 2d 1343 (Fla. 1st DCA 1989); Williams v. State, 522 So. 2d 983 (Fla. 1st DCA 1988); Smith v. State, 508 So. 2d 1292 (Fla. 1st DCA 1987); Neff v. State, 356 So. 2d 901 (Fla. 1st DCA 1978).
The evidence at the hearing below showed that Ms. Singletary’s illness manifests itself primarily in religious delusions. The mere fact of mental illness is insufficient justification for involuntary commitment. See Adams v. State, 713 So. 2d 1063 (Fla. 1st DCA 1998); Williams, 522 So. 2d at 984. See also Lyon v. State, 724 So. 2d 1241 (Fla. 1st DCA 1999); Salter v. State, 618 So. 2d 352 (Fla. 1st DCA 1993).
Many of her symptoms may be controlled by medication, the evidence showed, but doctors testified she has a tendency to neglect taking medications prescribed for her. Ms. Singletary’s mother, Roberta White, testified that she wanted her daughter to live with her. Ms. White testified she would ensure that her daughter continued to take her medication, and promised to initiate involuntary commitment proceedings if she did not. Ms. White testified that she intended to take Ms. Singletary out of what she perceived to be a harmful environment in their Jacksonville neighborhood and live instead with relatives in Jasper. Although the state presented witnesses who believed placement with Ms. Single-tary’s mother was not a viable alternative, they based their opinions on past experience in the neighborhood and failed to take into account the changes Ms. White proposed.
In light of Ms. White’s testimony, the state did not present clear and convincing evidence that less restrictive treatment alternatives were unavailable. See § 394.467(l)(b), Fla. Stat. (1997); LA. v. State, 530 So. 2d 489, 490 (Fla. 1st DCA 1988) (“[A] non-dangerous individual, capable of surviving safely in freedom by herself with the help of others, should not be involuntarily committed.”).
Finally, although the state presented vague testimony that Ms. Single-tary may have threatened others at some point in the past, it concedes on appeal that the testimony it adduced does not amount to clear and convincing evidence that she is currently a danger to others. See Schexnayder v. State, 495 So. 2d 850, 852 (Fla. 1st DCA 1986) (recognizing that, even though the problem may be an ongoing one, the court is bound to act on the record as presented at the time of involuntary placement).
Nor was the testimony that she would likely have to be rehospital-ized, if she did not take her medicine, sufficient to prove “a real and present threat of substantial harm to ... her well-being.” § 394.467(l)(a)2 a, Fla. Stat. (1999). The order granting the petition for involuntary placement is reversed.
ERVIN and BENTON, JJ., CONCUR; BOOTH, J„ DISSENTS.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
-
Boller v. State, 775 So. 2d 408 (Fla. 1st DCA 2000)…t proceeding, the State bears the burden of proving by clear and convincing evidence that the statutory criteria authorizing involuntary commitment have been met.” Blue v. State, 764 So. 2d 697, 698 (Fla. 1st DCA 2000); see also Singletary v. State, 765 So. 2d 180, 181 (Fla. 1st DCA 2000). It is well-settled that the need for treatment and medication and the refusal to take psychotropic medication despite a deteriorating mental condition, standing alone, do not justify involuntary commitment under the Baker A…
-
Lischka v. State, 901 So. 2d 1025 (Fla. 1st DCA 2005)…y clear and convincing evidence that the statutory criteria authorizing involuntary commitment have been met.” Blue v. State, 764 So. 2d 697, 698 (Fla. 1st DCA 2000); see also Boiler v. State, 775 So. 2d 408 (Fla. 1st DCA 2000); Singletary v. State, 765 So. 2d 180 (Fla. 1st DCA 2000). It is well-settled that the need for treatment and medication and the refusal to take medication despite a deteriorating mental condition, standing alone, do not justify involuntary commitment under the Baker Act. See Blue, 764…
-
D.F. v. State, 248 So. 3d 1232 (Fla. 5th DCA 2018)…commitment is necessary. In re Lehrke , 12 So. 3d 307, 308 (Fla. 2d DCA 2009). Importantly, the mere fact that an individual might suffer from a mental illness is not sufficient standing alone to justify involuntary commitment. Singletary v. State , 765 So. 2d 180, 181 (Fla. 1st DCA 2000). Rather, the State must also show that the party is likely to suffer neglect without treatment or that a substantial likelihood exists that the party will inflict serious bodily harm on himself in the near future, based upon…
Previewing 3 of 6 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited (16 total)
- In re Preer Beverly, 342 So. 2d 481 (Fla. 1977)
- Lyon v. State, 724 So. 2d 1241 (Fla. 1st DCA 1999)
- Smith v. State, 508 So. 2d 1292 (Fla. 1st DCA 1987)
- Jones v. State, 611 So. 2d 577 (Fla. 1st DCA 1992)
- Williams v. State, 522 So. 2d 983 (Fla. 1st DCA 1988)
- Welk v. State, 542 So. 2d 1343 (Fla. 1st DCA 1989)
- Adams v. State, 713 So. 2d 1063 (Fla. 1st DCA 1998)
- State v. Vasquez, 495 So. 2d 850 (Fla. 3d DCA 1986)
- Schexnayder v. State, 495 So. 2d 850 (Fla. 1st DCA 1986)
- State v. Wardlow, 356 So. 2d 901 (Fla. 2d DCA 1978)