In re Clinton S., 2016 IL App (2d) 151138

Clinton S., a 53‑year‑old with long history of mental illness (schizophrenia) and end‑stage renal failure, was committed to Elgin Mental Health Center after being found unfit to stand trial.
Treating psychiatrist Dr. Mirella Susnjar petitioned under 405 ILCS 5/2‑107.1 to involuntarily administer psychotropic medications and requested concurrent hemodialysis, which the nephrologist recommended three times weekly.
Susnjar testified respondent’s symptoms improved on prior antipsychotics but returned after he refused medication; he also refused hemodialysis after stopping meds.
Susnjar opined psychotropic drugs could cause toxic accumulation without dialysis, making dialysis ‘‘essential for the safe and effective administration’’ of the medications and necessary to prevent death from renal failure.
The trial court found by clear and convincing evidence that benefits of the proposed medication outweighed the harms (factoring in dialysis) and ordered the medications and hemodialysis for up to 90 days; respondent appealed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Clinton)	Held
Whether benefits of involuntary psychotropic medication outweighed harms under §2‑107.1(D)	Benefits (calming psychosis, restoring decision‑making, facilitating dialysis) outweigh risks when dialysis is provided	Benefits do not outweigh harms absent dialysis; court improperly relied on dialysis contingency beyond §2‑107.1 authority	Court affirmed: trial court permissibly considered dialysis in weighing risks/benefits; finding not against manifest weight of evidence
Whether court had authority under §2‑107.1(a‑5)(4)(G) to order hemodialysis as a procedure essential for safe administration	§2‑107.1 authorizes “testing and other procedures” essential to safe administration; dialysis authorized where clear and convincing evidence shows necessity	§2‑107.1 does not authorize invasive procedures like dialysis; such decisions should be made via guardianship/surrogate processes	Court affirmed: ordering dialysis was authorized under §2‑107.1 where evidence showed dialysis was essential for safe/effective administration and treatment plan was physician‑recommended

In re C.E., 161 Ill. 2d 200 (explaining §2‑107.1 purpose and parens patriae interest)
In re Robert S., 213 Ill. 2d 30 (noting severe liberty interests implicated by involuntary psychotropic drugs)
In re Alfred H.H., 233 Ill. 2d 345 (capable‑of‑repetition exception in mental‑health appeals)
In re Larry B., 394 Ill. App. 3d 470 (safeguards against misuse of psychotropic medication)
In re Val Q., 396 Ill. App. 3d 155 (court reversed where necessary medical consultation/testing was lacking)
In re Floyd, 274 Ill. App. 3d 855 (authorizing blood testing under §2‑107.1 to ensure safe administration)
In re Jill R., 336 Ill. App. 3d 956 (recognizing implied authority to order periodic blood testing under parens patriae)
In re Mary Ann P., 202 Ill. 2d 393 (treatment plan must be authorized in its entirety as recommended by treating physician)
In re Williams, 305 Ill. App. 3d 506 (treatment must be sufficiently defined to permit meaningful weighing of risks and benefits)