Background
D.G. was admitted to Peak View Behavioral Health for restoration after being found incompetent to proceed in a criminal case. He had diagnoses including paranoid schizophrenia, autism spectrum disorder, and bipolar disorder. During hospitalization, he displayed agitation, aggression, paranoia, threatening statements, and physical posturing that at times required restraints and emergency medication.
In March 2026, D.G.’s providers obtained an order for short-term care and treatment and involuntary medication. While his appeal was pending, the People sought an extension. After hearing testimony from D.G. and his treating psychiatrist, Dr. Julie Sanford, a magistrate extended short-term treatment for three months and authorized continued involuntary medication.
The Court’s Holding
The Colorado Court of Appeals affirmed. It held that clear and convincing evidence supported the finding that D.G. was gravely disabled because his thought disorder and mental illness prevented him from making thoughtful, considered decisions about everyday functioning and essential needs without significant supervision or assistance.
The court also upheld the medication order. D.G.’s ability to state preferences, request dosage reductions, and raise side-effect concerns did not establish that he could effectively participate in treatment decisions, given his denial of mental illness and refusal of all medication absent a court order. The magistrate could rely on Dr. Sanford’s testimony in finding that D.G.’s treatment need outweighed his objections, including reported headaches from Zyprexa.
Key Takeaways
- Grave disability may rest on a thought disorder that substantially impairs everyday decisionmaking, not merely combative or disagreeable behavior.
- A patient can articulate medication preferences yet still be incompetent to effectively participate in treatment decisions under Medina.
- Credible treating-physician testimony may be sufficient to satisfy the involuntary-medication standard.
Why It Matters
The decision illustrates the evidence Colorado courts may consider when extending short-term mental health treatment and authorizing forced medication. It also underscores that appellate courts defer to supported factual and credibility findings while reviewing the legal standards de novo.