In re Bobby F., 970 N.E.2d 25

Respondent Bobby F. was involuntarily ordered to receive psychotropic medications under 405 ILCS 5/2-107.1 following a certification of illness and alleged dangerous behavior.
The circuit court's April 13, 2011 order listed medications and allowed a “therapeutic dose” rather than specific dosages.
Hearing evidence showed respondent suffered from bipolar I with severe mania, aggression, and deteriorating function; less restrictive options had been attempted.
Dr. Casey testified to medications including Zyprexa, Depakote, Clonazepam, Haldol, and Ativan, with various dosages and titration.
The State sought to justify involuntary treatment but the order lacked written notice of risks, benefits, and alternatives to the medications, as required by statute.
Appellant appealed, and the case is reviewed under the public-interest mootness exception to determine whether the order complied with due process.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the order complied with 2-107.1(a-5)(6) requiring specificity of medications and dosage ranges.	People contends petition and hearing supported use of meds.	Bobby F. argues lack of explicit medication/dosage details.	Order reversed for lack of specific medications/dosage ranges.
Whether the state provided written notice of risks, benefits, and alternatives as required by 2-102(a-5).	People asserts written side effects were included in the petition.	Bobby F. lacked written notice of risks/benefits/alternatives beyond a petition.	Order reversed due to absence of required written information.
Whether failure to provide written information prevents a proper due-process determination.	People claims trial court had sufficient information to decide.	Bobby F. asserts lack of written notice taints due process.	We reverse; written notification is essential to due-process safeguards.
Whether the issue of dosage specification was waived and whether plain error allows review.	People contends waiver but court may address under plain error.	Bobby F. notes waiver by not objecting.	Issue addressed on merits; order reversed for failure to specify medications/dosages.

In re Williams, 305 Ill. App. 3d 506 (Ill. App. 2001) (strict compliance with 2-107.1(a-5) requires specify medications and dosages)
In re John R., 339 Ill. App. 3d 778 (Ill. App. 2003) (written notice and safeguards are essential to due process)
In re Louis S., 361 Ill. App. 3d 774 (Ill. App. 2005) (lack of written information requires reversal)
In re Laura H., 404 Ill. App. 3d 286 (Ill. App. 2010) (written notice of risks/benefits/alternatives necessary)
In re Frances K., 322 Ill. App. 3d 203 (Ill. App. 2001) (noncompliance with statutory safeguards is reversible)
In re A.W., 381 Ill. App. 3d 950 (Ill. App. 2008) (written advisement requirements not met)