In re Jian L., 95 N.E.3d 56

Jian L. voluntarily admitted himself to Presence Covenant Medical Center for psychiatric treatment in April 2017 and later (May 5) submitted a written request for discharge under the Mental Health and Developmental Disabilities Code (Code).
On May 5, the State filed a petition for involuntary admission under section 3-601, alleging Jian had a mental illness and posed a danger to himself or others; the petition included two certificates as required by the Code.
On May 11, Jian withdrew his written request for discharge and argued the involuntary-admission proceedings must stop because he was again willing to remain voluntarily admitted.
The trial court rejected Jian’s argument, held a hearing during which psychiatrist Feiting Su testified about Jian’s worsening schizoaffective disorder and dangerous behavior, and ordered involuntary admission for 90 days.
Jian appealed, contending (1) the court should not have adjudicated the State’s petition once he withdrew his discharge request, and (2) the certificates attached to the petition were not executed under penalty of perjury as required by section 3-203.

Issue	Plaintiff's Argument (People)	Defendant's Argument (Jian)	Held
Whether the State may continue involuntary-admission proceedings after a voluntary patient withdraws a written discharge request	The Code permits the State to proceed on a properly filed petition even if the patient withdraws the discharge request	Once the patient withdraws the discharge request, the State may no longer proceed on the petition filed under §3-403	Court held the State may continue proceedings; withdrawing the discharge request does not bar adjudication of a timely-filed petition
Whether the two certificates attached to the petition complied with §3-203 (execution under penalty of perjury)	Any technical defects in certificate verifications do not preclude adjudication where evidence supporting commitment was given under oath at the hearing	Certificates were not executed under penalty of perjury, so the involuntary-admission order is invalid	Court declined to reverse: deficiencies were technical and the petition’s allegations were tested under oath at the hearing; commitment stands

In re Alfred H.H., 233 Ill. 2d 345 (2009) (mootness exception: capable of repetition yet evading review)
In re Splett, 143 Ill. 2d 225 (1991) (voluntary patients may seek discharge and State may not file for involuntary commitment until patient requests discharge)
In re Wheeler, 152 Ill. App. 3d 371 (1987) (technical defects in petition/certificates do not necessarily defeat commitment when evidence supports the finding)
People v. Collins, 202 Ill. 2d 59 (2002) (purpose of pleading verifications is to ensure allegations are truthful and made in good faith)
In re Houlihan, 231 Ill. App. 3d 677 (1992) (statutory language involving involuntary commitment construed strictly in favor of the patient)