In re Katarzyna G., 995 N.E.2d 585

Respondent Katarzyna G., a Polish-born woman who communicates in Polish, was involuntarily admitted to Elgin Mental Health Center and diagnosed with a delusional (persecutory) disorder.
Since admission she refused psychotropic medications; her treating physician petitioned the court to involuntarily administer medications.
The physician provided written medication information in English only; Polish interpreters were used in meetings and at court, but the record shows no written materials in Polish.
The trial court granted the petition; respondent did not raise the language-of-notice issue below but timely appealed.
The appellate court considered mootness and forfeiture issues but reviewed the merits, concluding the record establishes respondent does not understand English and that the State failed to give written notice in a language she understands.

Issue	State's Argument	Respondent's Argument	Held
Whether the statutory required written notice about risks, benefits, side effects, and alternatives must be provided in a language the respondent understands	Written English notice plus access to a Polish interpreter sufficed; any error, if it existed, was harmless	Written notice was not provided in Polish; without written notice in a language she understands, respondent could not make a reasoned decision	Reversed: statute requires written notice in a language the recipient understands; oral translation/interpretation is insufficient and harmless-error analysis does not apply
Whether the appellate review was forfeited because respondent did not raise the notice-language claim below	The State suggested forfeiture at argument	Respondent argued the issue should be reviewed given public/liberty interests and the State did not preserve a forfeiture argument in its brief	Court declined to treat the issue as forfeited (State failed to preserve a forfeiture argument on appeal)

In re Cathy M., 326 Ill. App. 3d 335 (trial-court order to medicate must be supported by clear and convincing evidence respondent lacks capacity to decide)
In re R.C., 338 Ill. App. 3d 103 (statutory construction rules; legislative intent governs Code interpretation)
In re Nicholas L., 407 Ill. App. 3d 1061 (strict compliance required with written-notice requirement under section 2-102(a-5))
In re Richard C., 329 Ill. App. 3d 1090 (failure to give any written notice requires reversal of involuntary-medication order)
In re John R., 339 Ill. App. 3d 778 (written notice, not oral, is required; strict compliance mandated)
In re Louis S., 361 Ill. App. 3d 774 (written notice is an element the State must establish before involuntary medication can be ordered)