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Neutral Court Opinion May 15, 2026

Peo in Interest of Harris

── Peo in Interest of Harris ── Court: Colorado Court of Appeals Date: May 14, 2026 Category: General 26CA0407 Peo in Interest of Harris 05-14-2026 COLORADO COURT OF APPEALS Court of Appeals No. 26CA0407 City and County of Denver Probate Court No. 25MH830 Honorable Beth A. Tomerlin, Magistrate The People of the State of Colorado, Petitioner-Appellee, In the Interest of Lincoln Harris, Respondent-Appellant. ORDER AFFIRMED Division A Opinion by JUSTICE MARTINEZ* Román, C.J., and Hawthorne*, J., concur NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced May 14, 2026 Miko Brown, City Attorney, Hayley Swestka, Assistant City Attorney, Denver, Colorado, for Petitioner-Appellee Tezak Law, P.C., Mary Tezak, Florence, Colorado, for Respondent-Appellant *Sitting by assignment of the Chief Justice under provisions of Colo. Const. art. VI, § 5(3), and § 24-51-1105, C.R.S. 2025. ¶1 Respondent, Lincoln Harris, appeals a magistrate’s order authorizing his certification for long-term mental health treatment at the Colorado Mental Health Hospital in Pueblo (the hospital). We affirm. I. Background ¶2 In March 2025, Harris was admitted to the hospital for restoration treatment after being found incompetent to proceed in a criminal case. Less than two weeks later, the criminal court dismissed Harris’s charges, which prompted the hospital to request a seventy-two-hour mental health hold. The hospital then petitioned for short-term mental health treatment. ¶3 After extending the short-term certification, the hospital petitioned for long-term mental health treatment, alleging that Harris was gravely disabled. In February 2026, a magistrate held a hearing, at which Dr. Zachary Wickline (one of Harris’s treating physicians) and Harris testified. After hearing the evidence, the magistrate found that Harris was gravely disabled and granted the request for long-term certification. 1 II. Long-Term Certification ¶4 Harris asserts that there was insufficient evidence to establish that he was gravely disabled, and the magistrate therefore erred by authorizing the long-term certification. We are not persuaded. ¶5 When a patient challenges the sufficiency of the evidence, 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. As the fact finder, the magistrate determines the sufficiency, probative effect, and weight of the evidence, along with the inferences and conclusions to be drawn from it. People in Interest of R.C., 2019 COA 99M, ¶ 7. We must defer to the magistrate’s factual findings if they have record support, but we review the magistrate’s legal conclusions de novo. R.K.L., ¶ 13. ¶6 To authorize long-term certification for mental health treatment, the magistrate must find that the patient has a mental health disorder and, as a result of that disorder, is gravely disabled or a danger to themselves or others. § 27-65-110(1)(a), C.R.S. 2025. Gravely disabled means that, because of a mental health disorder, a person is incapable of making informed decisions about 2 or providing for their essential needs without significant supervision and assistance from other people. § 27-65-102(17), C.R.S. 2025; see also People v. Taylor, 618 P.2d 1127, 1134 (Colo. 1980) (noting that a person is gravely disabled if they cannot “take care of basic personal needs,” such as “food, shelter, clothing, and medical care”). ¶7 The magistrate determined that the evidence presented at the hearing established that Harris was gravely disabled as defined by section 27-65-102(17). In reaching this decision, the court pointed to the following evidence in the record:
CourtListener · May 14, 2026
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