Peo in Interest of Wolf

── Peo in Interest of Wolf ── Court: Colorado Court of Appeals Date: May 14, 2026 Category: General 26CA0548 Peo in Interest of Wolf 05-14-2026 COLORADO COURT OF APPEALS Court of Appeals No. 26CA0548 Pueblo County District Court No. 26MH30029 Honorable Amiel Markenson, Judge The People of the State of Colorado, Petitioner-Appellee, In the Interest of Stephen Christopher Wolf, 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 14, 2026 Cynthia Mitchell, County Attorney, Kate H. Shafer, Special Assistant County Attorney, Pueblo, Colorado, for Petitioner-Appellee Tezak Law, P.C., Mary Tezak, Florence, Colorado, for Respondent-Appellant ¶1 Stephen Christopher Wolf appeals the district court’s order authorizing the involuntary administration of medication. We affirm. I. Background ¶2 Wolf was committed to the Colorado Mental Health Hospital in Pueblo (CMHHIP) after being found incompetent to proceed in a criminal case. He was diagnosed with psychosis and displayed, among other things, paranoia and hallucinations. Wolf refused recommended medical treatment. ¶3 After he exhibited escalating aggression toward staff, including “swinging and kicking” at them, Wolf was given emergency medication. The People then petitioned for authorization to continue administering antipsychotic and mood stabilizing medications to Wolf. ¶4 At an evidentiary hearing, Dr. Hareesh Pillai — the psychiatrist supervising Wolf’s treatment — testified about Wolf’s history of mental illness and his diagnosed psychosis and accompanying symptoms. He also described the requested medications, how they treat Wolf’s mental illness, and the possible 1  side effects. And Dr. Pillai opined that the medications were necessary to treat Wolf’s mental illness. ¶5 Wolf also testified. He did not admit to having a mental illness. He explained that he wanted to participate in treatment decisions and described various side effects that he had experienced from the medications, including vertigo, sedation, drooling, and feeling like his “organs are failing.” ¶6 The district court granted the petition. It found that Dr. Pillai had testified “credibly and persuasively” and 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 issued an order authorizing the involuntary administration of the requested medications. II. Applicable Law and Standard of Review ¶7 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 2  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. Id.1 ¶8 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. It is for the district court, as the fact finder, to determine the credibility of witnesses; the sufficiency, probative effect, and weight of the evidence; and the inferences and conclusions to be drawn from the evidence. People in Interest of R.C., 2019 COA 99M,