In re Deborah S., 2015 IL App (1st) 123596

The State filed a petition (July 16, 2012) seeking respondent Deborah S.’s involuntary inpatient commitment to Chicago Lakeshore Hospital under the Illinois Mental Health Code, alleging psychosis and inability to meet basic physical needs.
Dr. Scott Feldman (treating psychiatrist) signed a certificate and testified he diagnosed psychosis NOS based on records, interviews and observations; he recommended a 90‑day inpatient commitment.
At the July 25, 2012 hearing respondent sought to discharge her court‑appointed counsel and proceed pro se; the trial court denied withdrawal after colloquy concluding she lacked the necessary legal understanding.
Evidence included testimony from respondent (she lived at a transitional facility, ate three meals a day, had ~$3,000 in tax refunds held by counsel, disputed husband over funds) and her sister (reported delusions, past weight loss, possible diabetes).
Trial court found the State met its burden by clear and convincing evidence and entered a 90‑day commitment; respondent appealed.
The appellate court held the case was not moot under the collateral‑consequences exception and reversed the commitment for insufficient clear and convincing evidence that respondent could not meet basic physical needs.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Deborah)	Held
Mootness / collateral consequences	Appeal moot because 90‑day order expired	Commitment has collateral consequences (driver’s license, employment, divorce), so review should proceed	Collateral‑consequences exception applies; appeal not dismissed
Denial of request to proceed pro se (§ 3‑805 standard)	Court properly ensured waiver of counsel was knowing and intelligent; appointment should remain	Court applied an impermissible or overly stringent standard and abused discretion in denying pro se request	Not reached on merits because reversal on sufficiency grounds (State conceded issues by failing to brief them)
Sufficiency of evidence for involuntary commitment (unable to meet basic physical needs)	Expert and family testimony showed delusions, poor hygiene, refusal of medical evaluation, risk of harm, lack of shelter	Respondent testified she ate three meals daily at transitional facility, had funds, sought medical care in 2011–2012, and planned to return to transitional housing	Reversed: State failed to prove by clear and convincing evidence respondent was unable to provide for basic physical needs; commitment against manifest weight of evidence

In re Alfred H.H., 233 Ill. 2d 345 (Illinois 2010) (mootness exceptions and collateral‑consequences analysis)
In re Rita P., 2014 IL 115798 (Illinois 2014) (collateral‑consequences exception does not automatically apply in first‑time commitment cases)
In re Splett, 143 Ill. 2d 225 (Illinois 1991) (stigma of involuntary admission can justify review)
In re Hays, 102 Ill. 2d 314 (Illinois 1984) (character of commitment supports invoking collateral‑consequences exception)
In re Alex T., 375 Ill. App. 3d 758 (Ill. App. Ct.) (applying collateral‑consequences exception in mental‑health case)
In re Sciara, 21 Ill. App. 3d 889 (Ill. App. Ct.) (same)
In re Jakush, 311 Ill. App. 3d 940 (Ill. App. Ct.) (standard of review and requirements for involuntary commitment)
In re Shirley M., 368 Ill. App. 3d 1187 (Ill. App. Ct.) (factors for assessing ability to meet basic physical needs)
In re Winters, 255 Ill. App. 3d 605 (Ill. App. Ct.) (weight to accord expert opinion depends on factual basis)
O'Connor v. Donaldson, 422 U.S. 563 (U.S. 1975) (lack of place to live alone not sufficient to confine a person)
In re Long, 237 Ill. App. 3d 105 (Ill. App. Ct.) (person may choose to live on the street)
In re Tuman, 268 Ill. App. 3d 106 (Ill. App. Ct.) (mental illness alone insufficient to show inability to guard against physical harm)
In re Rovelstad, 281 Ill. App. 3d 956 (Ill. App. Ct.) (on reasonableness of refusing to speak with evaluator)