In re Leo M.

Illinois Appellate Court
Civil Court
Involuntary Administration of Medication
Citation
Case Number: 
2022 IL App (5th) 190211
Decision Date: 
Thursday, September 15, 2022
District: 
5th Dist.
Division/County: 
Randolph Co.
Holding: 
Reversed.
Justice: 
BOIE

Respondent appealed from a medication order entered pursuant to the Mental Health and Developmental Disabilities Code finding him subject to involuntary administration of psychotropic medication. The appellate court reversed, finding that the case involved “multiple flagrant violations” of the Code’s requirements, including that the expert testimony was “minimal” and the hearing took only thirteen minutes. The appellate court also noted that the circuit court did not use the standardized form provided by the Illinois Supreme Court for the administration of authorized involuntary treatment. The court noted that the procedural provisions of the Code must be strictly construed in favor of the respondent. (CATES and BARBERIS, concurring)