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People in the Interest of Ramsey
Melody Ramsey appealed the probate court’s order certifying her for short-term involuntary treatment and authorizing the involuntary administration of antipsychotic, mood stabilizing and side-effect treating medications. She contended the court violated her rights and the evidence was insufficient to uphold the court’s order.
The Colorado Court of Appeals disagreed and unanimously affirmed the order.
In May 2023, Ramsey was living without a home and was arrested for trespassing at an encampment. She spent one night in the Denver County Jail. When the police released her, she refused to leave and insisted they file a report on her allegations her court-appointed guardian was abusing her. The jail’s psychiatric team suspected she was suffering from paranoia and delusions, so they placed her on a mental health hold. She was transported to Denver Health Medical Center May 20 where the staff in the emergency room found her to be paranoid, delusional, irritable and unstable, the opinion noted. DHMC admitted Ramsey into an adult inpatient unit and her treating psychiatrist diagnosed her with a delusional disorder.
DHMC filed its first notice of certification, certification for short-term treatment and a motion for involuntary medication administration authority in the Denver Probate Court May 24 and the court-appointed counsel for Ramsey. On Ramsey’s counsel’s motion, the probate court dismissed that case June 2 due to a procedural defect. Later that day, DHMC filed a substantively identical second petition that cured the procedural defect. The probate court reappointed Ramsey’s previous counsel June 2 and scheduled a hearing on the second petition for June 6.
Ramsey’s counsel filed a motion to dismiss on statutory grounds and a motion to continue and for discovery, arguing more time was required to obtain and review Ramsey’s medical records and for her to undergo a complete medical examination. At the June 6 hearing, the probate court denied both motions and the hearing proceeded as scheduled.
Ramsey and her treating psychiatrist testified at the hearing. The treating psychiatrist was endorsed without objection as an expert in psychiatry and she testified about diagnosing Ramsey with delusional disorder and what the diagnosis meant. The treating psychiatrist then opined that Ramsey’s delusional disorder caused her to be unable to control her behavior and resulted in a substantial disorder of her cognitive abilities, her ability to recognize reality and her emotional processes. Because of this disorder, the treating psychiatrist concluded Ramsey was disabled.
The probate court upheld the certification for short-term treatment, made findings on the four required elements in the 1985 Colorado Supreme Court decision in People v. Medina, and granted the people’s motion for involuntary medication administration authority. Shortly thereafter, the court issued a written order consistent with its oral ruling.
Ramsey appealed the probate court’s order, contending the court violated her due process rights by denying her continuance motion. In the alternative, Ramsey contended the evidence was insufficient to support the court’s findings she was mentally ill or gravely disabled and all four Medina elements were met. The Colorado Court of Appeals disagreed with her contentions.
After evaluation, the Colorado Court of Appeals affirmed the order.
The prior opinion announced August 24 was withdrawn. The opinion previously announced as “not published pursuant to C.A.R. 35(e)” Aug. 24 is now designated for publication.