In re Amanda H.
2017 IL App (3d) 150164
| Ill. App. Ct. | 2017Background
- Respondent Amanda H. was brought to Riverside Medical Center after family called police and paramedics; police and paramedics restrained and transported her against her will.
- State filed petitions for involuntary admission (Jan 14, 2015) and involuntary administration of psychotropic medication (Jan 16, 2015).
- At hearing, treating psychiatrist (Dr. Belford) diagnosed bipolar disorder, manic with psychosis, recommended up to 90 days’ inpatient commitment; respondent denied mental illness and refused medication.
- No written predispositional report (Section 3-810) was filed; State relied on Dr. Belford’s testimony.
- Trial court granted involuntary admission and involuntary medication orders; respondent appealed after discharge (commitment term expired), raising statutory-compliance and sufficiency arguments.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Mootness — reviewable exceptions | Amanda: appeal falls within capable-of-repetition and public-interest exceptions because statutory interpretation issues may recur | People: orders expired so appeal is moot | Court: exceptions apply — capable-of-repetition (and public-interest for §3-606 issue); review allowed |
| §3-606 — failing to identify transporting officers in petition | Amanda: petition omitted names/badge numbers of police who helped transport her, as §3-606 requires, risking prejudice | People: issue forfeited (no trial objection) and any error harmless | Court: §3-606 required inclusion here because police actively restrained/transported her; omission was potentially prejudicial; merits considered despite forfeiture |
| §§3-810 & 3-811 — predisposition report and least-restrictive-alternative | Amanda: State failed to file written predisposition report and testimony was conclusory about alternatives, so court didn’t consider available/appropriate less-restrictive options | People: respondent forfeited by not objecting at trial; oral testimony sufficed | Court: reversal — no written report and Dr. Belford’s testimony was cursory (no specific alternatives, treatment plan, timetables, or social investigation), so statutory requirements unmet and commitment was reversible error |
| Involuntary medication order dependent on admission | Amanda: medication order invalid because commitment was invalid; alternatively, State failed to meet statutory prerequisites for medication | People: medication order proper | Court: because admission order is reversed, respondent is no longer a "recipient of services" and medication order reversed; no remand — State must reinitiate new proceedings if desired |
Key Cases Cited
- In re Robert S., 213 Ill. 2d 30 (recognizing public-interest mootness exception and procedural concerns in involuntary-commitment cases)
- Alfred H.H. v. In re, 233 Ill. 2d 345 (defining three mootness exceptions and their application)
- In re Barbara H., 183 Ill. 2d 482 (capable-of-repetition standard for short-duration commitments)
- Robinson v. In re, 151 Ill. 2d 126 (oral testimony can substitute for predispositional report only if it supplies the statute’s required specifics)
- In re Daryll C., 401 Ill. App. 3d 748 (reversing commitment where testimony failed to address availability/appropriateness of alternatives)