In re Linda B., 29 N.E.3d 406

Petition filed May 9, 2013 by Mount Sinai Hospital director seeking emergency inpatient admission by certificate for Linda B. on April 22, 2013.
Respondent admitted to the hospital’s medical floor (not the psychiatric unit) on April 22, 2013 for tachycardia and severe anemia, with prior January psychiatric unit admission.
Certificates by Dr. Gartel and social worker Kurtz opined respondent mentally ill, unable to care for herself, and refusing treatment.
Circuit court granted involuntary medication on May 14, 2013; at a June 11, 2013 hearing, Dr. Mirkin testified respondent needed inpatient treatment; petition for involuntary admission was challenged as untimely.
Circuit court denied defense motion to dismiss; judge found respondent subject to inpatient involuntary admission and ordered treatment at Park Shore Nursing Home for up to 90 days.
On appeal, issue mootness due to expiration of the 90-day hospitalization period, but the public-interest exception to mootness applied; petition timeliness under section 3-611 was reviewed and ultimately affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the petition was timely under section 3-611.	People contend 3-611 timing triggered by article VI admission.	Linda B. argues admission as treated on medical floor is not article VI admission.	Timely under 3-611; 24-hour filing not triggered by medical-floor admission.
Whether mootness applies and public-interest exception governs.	People rely on mootness; public-interest exception supports review.	Linda B. argues moot because 90-day period expired; capab. of repetition unclear.	Public-interest exception applies; review on merits preserved.
Whether respondent was in a ‘mental health facility’ triggering 3-611.	People treat hospital unit as mental health facility for 3-611 purposes.	Respondent was on a medical floor, not admitted under article VI.	Not barred by 3-611; unit-specific facility interpretation valid.
Whether the admission was proper given the hospital’s unit designation.	Petition supported by medical-psychiatric oversight within the hospital.	Petition relies on wrong admission classification; not within 3-611 scope.	Petition timely; hospital unit distinction sustains validity.

In re Andrew B., 237 Ill. 2d 337 (Ill. 2010) (sets forth 3-611 timing and 24-hour filing for emergency involuntary admission)
In re Laura H., 404 Ill. App. 3d 286 (Ill. App. 2010) (public-interest mootness exception applicability criteria)
In re Lance H., 2014 IL 114899 (Ill. 2014) (public-interest mootness discussed; authority guiding future cases)
In re Robin C., 395 Ill. App. 3d 958 (Ill. App. 2009) (illustrates public-interest considerations in mootness)
In re India B., 202 Ill. 2d 522 (Ill. 2002) (discusses mootness and exception framework)