In re Amanda H.
79 N.E.3d 215
| Ill. App. Ct. | 2017Background
- Amanda H. was involuntarily transported to Riverside Medical Center after family concerns and police/paramedic involvement; psychiatrists at Riverside recommended inpatient commitment for suicidal/psychotic behavior.
- The State filed petitions for (1) involuntary admission (90 days) and (2) involuntary administration of psychotropic medication; hearings were held and both petitions were granted by the trial court.
- At hearing, State witnesses (brother, Dr. Belford) testified to Amanda’s suicidal statements, religiously themed psychosis, agitation, and refusal to accept treatment; Dr. Belford diagnosed bipolar disorder with psychosis and recommended inpatient treatment.
- The petition for admission was completed by Amanda’s father and did not identify the police officers who assisted in transporting Amanda; no written predisposition report (per 405 ILCS 5/3-810) was filed by the State.
- Amanda appealed arguing statutory violations: failure to identify transporting officers (§3-606), failure to file or present required predispositional information (§3-810/3-811), and insufficient evidence for commitment and involuntary medication; court considered mootness and exceptions.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Amanda) | Held |
|---|---|---|---|
| Mootness / reviewability of expired 90‑day orders | Appeal moot but exceptions may apply; encourages limited review | Case fits capable‑of‑repetition and public‑interest exceptions | Court applied capable‑of‑repetition and public‑interest exceptions and reached merits |
| §3‑606 — identification of transporting police officers in petition | Omission was harmless and forfeited by failure to object below | Petition violated §3‑606 because officers who restrained/transferred Amanda were not listed, prejudicing her ability to call them | Court: §3‑606 required identifying transporting officers here; omission not plainly harmless; reversible error potential |
| §3‑810 / §3‑811 — written predisposition report and consideration of least restrictive alternative | Substituted oral testimony can suffice where respondent fails to object; State relied on Dr. Belford’s testimony | Failure to file written report plus cursory testimony about alternatives (no specifics, no treatment plan, no timetables) violated §3‑810/3‑811 | Court: No written report filed and oral testimony was conclusory; statutory requirements not met; commitment reversed |
| Involuntary medication order | Medication order valid if commitment valid and statutory prerequisites met | Medication order invalid if commitment reversed or prerequisites not proven | Court: Because commitment reversed, medication order reversed as respondent no longer a "recipient of services" |
Key Cases Cited
- In re Robert S., 213 Ill. 2d 30 (mootness/public‑interest principles in involuntary commitment appeals)
- In re Alfred H.H., 233 Ill. 2d 345 (exceptions to mootness; capable‑of‑repetition standard)
- In re Barbara H., 183 Ill. 2d 482 (short‑duration proceedings and reviewability)
- Robinson v. Department of Mental Health, 151 Ill. 2d 126 (oral testimony may substitute for predispositional report only if it supplies statutory specifics)
- In re Rita P., 2014 Ill. 115798 (public‑interest exception and limits on case‑specific sufficiency review)
- In re Joseph P., 406 Ill. App. 3d 341 (strict compliance with procedural safeguards; potential prejudice from omitted statutory information)
- In re Alaka W., 379 Ill. App. 3d 251 (conclusory testimony insufficient to substitute for written predispositional report)
- In re Daryll C., 401 Ill. App. 3d 748 (reversal where testimony did not identify available alternatives or explain why inappropriate)
- In re Daniel M., 387 Ill. App. 3d 418 (cursory testimony about least‑restrictive alternative inadequate)
- In re Robin C., 395 Ill. App. 3d 958 (failure to file report and lack of detailed testimony requires reversal)