CourtListener 10855974•Peo in Interest of Castello
Texto completo
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,
1
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.
2
¶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.
3
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
4
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.
5
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
6
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
7
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
8
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.
9
¶ 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.
10
Continue sua pesquisa no ChatGPT ou Claude
Conecte o Omnilex para pesquisar o corpus jurídico pelo seu assistente de IA.