Peo in Interest of Castello

26CA0555 Peo in Interest of Castello 05-07-2026

COLORADO COURT OF APPEALS

Court of Appeals No. 26CA0555
Arapahoe County District Court No. 26MH130
Honorable Harold Clayburn Hurst, Judge

The People of the State of Colorado,

Petitioner-Appellee,

In the Interest of Trenton Castello,

Respondent-Appellant.

ORDER AFFIRMED

Division I
Opinion by JUDGE DUNN
J. Jones and Fox, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e)
Announced May 7, 2026

Ronald Carl, County Attorney, Meghan Rubincam, Senior Assistant County
Attorney, Aurora, Colorado, for Petitioner-Appellee

Tezak Law, P.C., Mary Tezak, Florence, Colorado, for Respondent-Appellant
¶1 Trenton Castello appeals the district court’s order certifying

him for short-term treatment and authorizing the involuntary

administration of several medications. We affirm.

I. Background

¶2 Castello has a longstanding history of schizoaffective disorder

that has required multiple psychiatric hospitalizations over the past

ten years. In February 2026, Castello was involuntarily admitted to

Bridge House, experiencing delusions, hallucinations, and

disorganization. He also exhibited negative symptoms, including

poverty of thought, thought blocking, and speech latency. This was

Castello’s third hospitalization within the past year.

¶3 A Bridge House physician requested that Castello be certified

for short-term mental health treatment under section 27-65-109,

C.R.S. 2025, and a separate psychiatrist sought an order

authorizing the involuntary administration of four antipsychotic

medications, one mood stabilizer, an anti-anxiety medication, and a

medication to treat side effects.

¶4 After Castello objected, the district court held an evidentiary

hearing. Castello did not appear at the hearing, but the court

heard testimony from his treating psychiatrist. After the hearing,

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the court entered an order certifying Castello for short-term

treatment. The court found by clear and convincing evidence that

Castello has a mental health disorder, is gravely disabled, and had

refused voluntary treatment. And finding that the People had

proved all four elements of the test set forth in People v. Medina,

705 P.2d 961, 973 (Colo. 1985), the court also authorized the

involuntary administration of all but one of the requested

medications.

II. Short-Term Certification

¶5 Castello first argues that the evidence was insufficient to

support the district court’s finding that he was gravely disabled,

and therefore the district court erred by certifying him for short-

term treatment. We disagree.

A. Applicable Law and Standard of Review

¶6 A district court may certify a person for involuntary short-term

treatment if it finds, by clear and convincing evidence, that the

person has a mental health disorder and, as a result, is a danger to

himself or others or is gravely disabled. §§ 27-65-109(1)(a), 27-65-

113(1), C.R.S. 2025.

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¶7 As relevant here, a person is “gravely disabled” when he is

“incapable of making informed decisions about or providing for [his]

essential needs without significant supervision and assistance from

other people.” § 27-65-102(17), C.R.S. 2025. As a result of the

inability to make informed decisions, a gravely disabled person is at

risk of, among other things, “significant psychiatric deterioration, or

mismanagement of the person’s essential needs that could result in

substantial bodily harm.” Id.; see also People v. Taylor, 618 P.2d

1127, 1134 (Colo. 1980) (interpreting “basic personal needs” to

mean “those fundamental necessities of human existence,”

including “food, shelter, clothing, and medical care”).

¶8 Whether a person is gravely disabled is a fact-specific

determination that depends on the person’s condition at the time

the finding is made. People in Interest of Vivekanathan, 2013 COA

143M, ¶ 14. We review the record as a whole and in the light most

favorable to the People to determine whether the evidence is

sufficient to support the district court’s decision. People in Interest

of Ramsey, 2023 COA 95, ¶ 23. We defer to the court’s factual

findings if sufficient record evidence supports them. Id.

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B. Grave Disability

¶9 The district court found that Castello is gravely disabled

because his mental illness is “impacting his ability to recognize

reality” and “his ability to take care of himself.” The court also

found that without treatment Castello would “significantly

deteriorate” and is at “risk of harm to his life.”

¶ 10 The record supports these findings. The psychiatrist testified

that Castello is “extremely” delusional, disoriented, and

disorganized. She explained that Castello “is unsure of his own

identity,” and believes that he is dead, his kidney has been

removed, he swallowed something that caused his voice to change,

he has bilateral frostbite in his hands and feet, and his mother has

been replaced by an imposter. The psychiatrist testified that “this

is not somebody who would [be] able to take care of themselves at

all, if they left the hospital.” And she expressed concerns that

Castello was “not improving” and “his presentation continues to get

worse,” including admitted suicidal thoughts.

¶ 11 Arguing that he is not gravely disabled, Castello emphasizes

that he is eating regularly, maintains personal hygiene, and can

communicate his needs effectively with his treatment team. He also

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argues that his expressed housing preference and access to family

support indicate that he can make informed decisions regarding his

care and living arrangements.

¶ 12 True, the psychiatrist testified that Castello “is eating fine,” is

“physically able-bodied,” is “able to ask for his needs,” “has family

support,” and has “[a]ccess to shelter.” But the psychiatrist also

testified that Castello would not be able to care for himself “at all” if

he left the hospital. She explained that he lacks insight into “his

ability to care for himself,” “has never been able to work,” and is

“not . . . able to go in[to] the community safely alone.”

¶ 13 Viewing the record as a whole and in the light most favorable

to the People, we conclude that this evidence is sufficient to support

the district court’s finding that Castello is gravely disabled. See

§ 27-65-102(17); see also Ramsey, ¶ 23 (“The resolution of conflicts

in testimony and determinations of the credibility of the witnesses

are solely within the province of the fact finder.”). Thus, the court

did not err by certifying Castello for short-term treatment.

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III. Involuntary Administration of Medication

¶ 14 Castello next contends that the evidence was insufficient to

support the district court’s order authorizing the involuntary

administration of medication to him. We disagree.

A. Applicable Law and Standard of Review

¶ 15 A district court may order the involuntary administration of

medication if the People prove by clear and convincing evidence that

(1) the patient is incompetent to effectively participate in the

treatment decision; (2) the treatment is necessary to prevent a

significant and likely long-term deterioration in the patient’s mental

health condition or to prevent the likelihood of the patient causing

serious harm to himself or others at the institution; (3) a less

intrusive treatment alternative is not available; and (4) the patient’s

need for treatment is sufficiently compelling to override any bona

fide and legitimate interest of the patient in refusing treatment.

Medina, 705 P.2d at 973.

¶ 16 Application of the Medina test involves mixed questions of fact

and law. People v. Marquardt, 2016 CO 4, ¶ 8. We defer to the

district court’s factual findings if they have record support and

review its legal conclusions de novo. Id. When a patient challenges

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the sufficiency of the evidence supporting an involuntary

medication order, we must affirm if the evidence, viewed as a whole

and in the light most favorable to the People, is sufficient to support

the order. People in Interest of R.K.L., 2016 COA 84, ¶ 13. The

treating psychiatrist’s testimony alone may suffice. Id. at ¶ 30.

B. Need for Treatment and Legitimate Interest in Refusing
Treatment

¶ 17 Castello challenges only the fourth Medina element; he

contends that the evidence was insufficient to prove that his need

for the requested medications is sufficiently compelling to override

his bona fide and legitimate interest in refusing to take them.

¶ 18 In assessing this element, a court must first determine

“whether the patient’s refusal is bona fide and legitimate.” Medina,

705 P.2d at 974. If it is, the court must then determine “whether

the prognosis without treatment is so unfavorable that the patient’s

personal preference must yield to the legitimate interests of the

state in preserving the life and health of the patient placed in its

charge and in protecting the safety of those in the institution.” Id.

¶ 19 Castello contends that the state’s interest in treating him is

insufficient to overcome his bona fide and legitimate interest in

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avoiding “potential side effects” of the requested medications. In

support, he (1) recounts the testimony from the psychiatrist who

explained the possible side effects associated with each of the

requested medications; and (2) argues that given the severity of

these possible side effects, his refusal is reasonable, considered,

and rational.

¶ 20 But nothing in the record suggests that Castello refused

medication because of possible side effects. Castello didn’t testify,

so we don’t know if he had concerns about potential side effects.

And the psychiatrist did not testify that Castello raised any

concerns about side effects or that he had experienced any side

effects. The only concerns about the medications that Castello

raised with the psychiatrist were (1) his belief that medications had

“killed him in the past”; and (2) that he did not want to be labeled “a

psychotic.”

¶ 21 Addressing these two stated concerns, the district court noted

that the first was “not based in . . . reality” given that Castello is

“clearly alive.” As to the second concern, the court weighed

Castello’s desire “to avoid a label,” against his serious prognosis

without treatment. And the court found the prognosis sufficiently

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compelling to override Castello’s concern. The court also noted that

there was no testimony that Castello had any physical ailments that

would be “contraindicated with treatment” and that he had been

treated successfully on antipsychotic medication in the past.

¶ 22 The district court’s findings have record support. The

psychiatrist testified that Castello’s prognosis without treatment is

“[s]ignificantly bad,” and “[a]t worst, it’s death.” She stressed that

Castello “has already decompensated,” and “needs meds yesterday.”

The psychiatrist also testified that there is no alternative medical

explanation for his symptoms and many of the physical maladies he

has complained of are unsubstantiated. And she confirmed that no

alternative treatment is available to treat Castello’s illness and that

his mother reported improvement with certain antipsychotics in the

past.

¶ 23 We acknowledge Castello’s stated concerns about the

medication and the stigma that can be associated with taking these

medications. But sufficient evidence supports the court’s finding

that the need to treat him is sufficiently compelling to override his

concerns. See R.K.L., ¶¶ 13, 30.

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¶ 24 Thus, we conclude the evidence was sufficient to support the

order authorizing the administration of involuntary medication.

IV. Disposition

¶ 25 The order is affirmed.

JUDGE J. JONES and JUDGE FOX concur.

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