In re Carolyn J.S.

Illinois Appellate Court
Civil Court
Mental Health and Developmental Disabilities Code
Citation
Case Number: 
2024 IL App (3d) 220250
Decision Date: 
Tuesday, April 23, 2024
District: 
3d Dist.
Division/County: 
DuPage Co.
Holding: 
Reversed.
Justice: 
McDADE

Respondent appealed from an order of the circuit court finding her subject to involuntary admission under the Mental Health and Developmental Disabilities Code. The appellate court reversed the circuit court’s judgment, finding that a mid-hearing amendment to the petition for involuntary admission altered the quality and nature of proof necessary and, as a result, the circuit court violated respondent’s right to due process by allowing the amendment and granting the motion for leave to amend was an abuse of discretion. (HOLDRIDGE, concurring and DAVENPORT, dissenting)