Peo in Interest of Snyder

25CA0576 Peo in Interest of Snyder 06-12-2025

COLORADO COURT OF APPEALS

Court of Appeals No. 25CA0576
Arapahoe County District Court No. 25MH108
Honorable H. Clay Hurst, Judge

The People of the State of Colorado,

Petitioner-Appellee,

In the Interest of Patrick Snyder,

Respondent-Appellant.

ORDER AFFIRMED

Division V
Opinion by JUDGE JOHNSON
Welling and Grove, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e)
Announced June 12, 2025

Ron 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 Patrick Snyder (Snyder) appeals the district court’s order

certifying him for long-term care and treatment. He contests the

sufficiency of the evidence supporting the order. We affirm.

I. Background

¶2 Snyder has been a client of Aurora Mental Health & Recovery

(AMHR) since 2020. He has a longstanding history of psychiatric

hospitalizations and difficulty following through with treatment

recommendations, including maintaining compliance with

prescribed antidepressant, mood-stabilizing, and antipsychotic

medications.

¶3 Snyder was originally certified for short-term treatment at

AMHR. On February 26, 2025, his treatment provider, Dr. Kris

Olson (Dr. Olson), filed a petition for long-term certification on an

outpatient basis. The petition alleged that Snyder is a danger to

others and is gravely disabled. Although Snyder had accepted

voluntary treatment, the petition alleged that reasonable grounds

existed to believe that he would not remain in a voluntary treatment

program.

1
¶4 The district court held a hearing on the matter and entered an

order confirming the long-term certification. As relevant here, the

court found by clear and convincing evidence that (1) Snyder is

gravely disabled as a result of his mental health disorder and (2)

reasonable grounds exist to believe he will not remain in treatment

voluntarily, notwithstanding his previous acceptance of treatment.

The court rejected the allegation that Snyder is a danger to others.

II. Standard of Review and Applicable Law

¶5 In reviewing the sufficiency of the evidence in a mental health

proceeding, we determine whether the evidence, viewed as a whole

and in the light most favorable to the petitioning party, is sufficient

to support the court’s order. People in Interest of R.K.L., 2016 COA

84, ¶ 13. We defer to the court’s factual findings if there is evidence

supporting them, but we review the court’s legal conclusions de

novo. People in Interest of Strodtman, 293 P.3d 123, 131 (Colo. App.

2011).

¶6 Under specified circumstances, section 27-65-110, C.R.S.

2024, permits a professional in charge of a patient’s short-term

2
certification and treatment to file a petition to certify the patient for

long-term care and treatment. See § 27-65-110(1); see generally

Perreira v. State, 768 P.2d 1198 (Colo. 1989) (providing an overview

of the certification process). As relevant here, to authorize long-

term certification for mental health treatment, a court must find by

clear and convincing evidence that the patient (1) has a mental

health disorder and, as a result, is gravely disabled or a danger to

himself or others; and (2) has been advised of the availability of, but

has not accepted, voluntary treatment. §§ 27-65-110(1)(a)-(b), 27-

65-113(1), C.R.S. 2024. Clear and convincing evidence is “evidence

that is highly probable and free from serious or substantial doubt.”

Destination Maternity v. Burren, 2020 CO 41, ¶ 10 (citation omitted).

If reasonable grounds exist to believe that the patient will not

remain in a voluntary treatment program, however, the patient’s

acceptance of voluntary treatment does not preclude a long-term

certification order. § 27-65-110(1)(b).

3
III. Analysis

¶7 Snyder contends that insufficient evidence supports the

district court’s conclusion that he is gravely disabled. He further

contends that the district court erred by finding that reasonable

grounds exist to believe that he will not remain in treatment

voluntarily. We reject these contentions.

A. Gravely Disabled

¶8 “Gravely disabled” means that, due to a mental health

disorder, a person 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. 2024.

As a result, such a person “is at risk of substantial bodily harm,

dangerous worsening of any concomitant serious physical illness,

significant psychiatric deterioration, or mismanagement of the

person’s essential needs that could result in substantial bodily

harm.” Id. A person is gravely disabled if he is “unable to take care

of basic personal needs.” People v. Taylor, 618 P.2d 1127, 1134

(Colo. 1980). Basic personal needs means “those fundamental

necessities of human existence, such as food, shelter, clothing, and
4
medical care, which an individual must obtain and maintain in

order to live safely.” Id.

¶9 Snyder asserts that the evidence does not support a finding

that he is gravely disabled because Dr. Olson testified that, “at one

time,” Snyder was “capable of making decisions about or providing

for his essential needs without significant supervision from others”

and was able to “make his own meals and those sorts of things.”

But Dr. Olson testified that his ability to care for himself was “in the

past when he was . . . better medicated,” and that he is not

presently able to “effectively participate in treatment planning in his

psychiatric care” due to “his lack of understanding or acceptance

of . . . having a mental illness.” And she testified that Snyder

currently resides in an assisted living facility, to which a team at

AMHR helped him get admitted and without which he would have

“nowhere to go.”

¶ 10 Dr. Olson noted that the staff at the assisted living facility

provides medication management and meals, and the facility is a

safe place to live. And she testified that Snyder is not currently

5
capable of “making informed decisions about his mental health

treatment and [the] medications that he needs.” Finally, she stated

that, if his certification was terminated, his prognosis would be poor

because she would expect that he would cease taking his

medications, his psychotic symptoms would increase, and his mood

and instability “would be worse.” As result, her expert opinion was

that Snyder is gravely disabled as a result of his mental illness.

¶ 11 Under these circumstances, we perceive no error in the district

court’s determination that Snyder is gravely disabled. The record

supports the determination that Snyder is presently reliant on

others to make certain informed decisions and for certain essential

needs, and that he is at risk for serious deterioration without “all

the supports that he’s relying on right now.”

¶ 12 We are not persuaded otherwise by Snyder’s reliance on his

own recognition that he “[p]robably” has a mental health disorder

and accepts the fact that he needs to be treated but would like to

choose a different provider. These facts do not undermine Dr.

Olson’s testimony, which the district court found “most credible.”

6
B. Reasonable Grounds

¶ 13 Snyder also asserts that the record does not support the

court’s finding that reasonable grounds exist to believe that he will

not remain in a voluntary treatment program. He relies on Dr.

Olson’s testimony that he resides at the assisted living facility

voluntarily, as well as his testimony that he does not contest his

need for treatment. Be that as it may, Dr. Olson’s certification

statement — on which the court relied — represented that such

reasonable grounds existed. Dr. Olson testified that although

Snyder had expressed a desire to find a different care provider, she

was not confident that “he would stay in care with another

provider,” in part because of his history of ceasing medications, and

in part because he had expressed a desire to leave the state.

¶ 14 Thus, we conclude that sufficient evidence supports the

court’s determination.

IV. Conclusion

¶ 15 The order is affirmed.

JUDGE WELLING and JUDGE GROVE concur.

7