In re Clinton S. , 2016 IL App (2d) 151138 ( 2017 )

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In re Clinton S., 2016 IL App (2d) 151138Appellate Court In re CLINTON S., Alleged to be a Person Subject to Involuntary
Caption Administration of Psychotropic Medication (The People of the State
of Illinois, Petitioner-Appellee, v. Clinton S., Respondent-Appellant).
District & No. Second District
Docket No. 2-15-1138
Filed December 2, 2016
Rehearing denied March 21, 2017
Decision Under Appeal from the Circuit Court of Kane County, No. 15-MH-88; the
Review Hon. Divya Sarang, Judge, presiding.
Judgment Affirmed.
Counsel on Veronique Baker, of Guardianship and Advocacy Commission, of
Appeal Chicago, and Cynthia Z. Tracy, of Guardianship and Advocacy
Commission, of Peoria, for appellant.
Joseph H. McMahon, State’s Attorney, of St. Charles (Patrick
Delfino, Lawrence M. Bauer, and Diane L. Campbell, of State’s
Attorneys Appellate Prosecutor’s Office, of counsel), for the People.
Panel JUSTICE HUTCHINSON delivered the judgment of the court, with
opinion.
Justices Birkett and Spence concurred in the judgment and opinion.
OPINION
¶1 Respondent, Clinton S., had a long history of mental health issues. He had also been
diagnosed with end-stage kidney failure. In granting a petition for the involuntary
administration of psychotropic medication pursuant to section 2-107.1 of the Mental Health
and Developmental Disabilities Code (Mental Health Code) (405 ILCS 5/2-107.1 (West
2014)), the trial court also ordered that respondent undergo regular hemodialysis treatments.
This was based on evidence that hemodialysis was essential for the safe and effective
administration of the medication, as respondent’s kidneys could not otherwise filter the
chemicals from his blood. Respondent appeals, arguing that (1) the State failed to prove by
clear and convincing evidence that the benefits of the medication outweighed the harm, and
(2) the trial court’s order exceeded the scope of the testing and other procedures that are
authorized under section 2-107.1. We affirm.
¶2 I. BACKGROUND
¶3 Respondent was admitted to the Elgin Mental Health Center (EMHC) on February 5,
2015, after being found unfit to stand trial on a robbery charge. He had been hospitalized for
issues related to his mental health over 40 times since 1980. At the time of these proceedings,
respondent was 53 years old.
¶4 On July 23, 2015, the State filed a petition for the involuntary administration of
psychotropic medication pursuant to section 2-107.1 of the Mental Health Code. Dr. Mirella
Susnjar signed the petition as respondent’s treating psychiatrist. In addition to seeking the
involuntary administration of several medications, Susnjar requested that respondent be
ordered to undergo regular hemodialysis treatments, which she deemed essential for the safe
and effective administration of the requested medications. Susnjar noted that respondent was
suffering from end-stage kidney failure, and she asserted that hemodialysis was necessary to
prolong his life.1
¶5 The trial court conducted a hearing on the petition on August 21, 2015. Susnjar was the
only witness to testify. The parties stipulated that Susnjar was an expert in the field of
psychiatry. Susnjar testified that she had performed a psychiatric evaluation on respondent
and had diagnosed him with schizophrenia. Susnjar explained that respondent suffered
hallucinations and delusions, heard voices, talked to himself, and struggled to converse with
other people. Respondent also occasionally became angry and violent. In one instance, he
threw a food tray and threatened to kill a nurse. Susnjar testified that respondent’s symptoms
had not improved from less restrictive treatments such as “one-to-one” and group therapies.
She did not believe that respondent was likely to stabilize without psychotropic medication.
She had checked respondent’s medical records and consulted with his assigned social
worker, but she was unable to determine whether respondent had executed a power of
attorney for health care or a declaration under the Mental Health Treatment Preference
Declaration Act (755 ILCS 43/1 et seq. (West 2014)).
The Mayo Clinic website describes “hemodialysis” as a procedure used for the treatment of
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advanced kidney failure in which a machine is used to filter wastes, salts, and fluid from the blood.
Hemodialysis, Mayo Clinic, http://www.mayoclinic.org/tests-procedures/hemodialysis/home/ovc-
20229742 (last visited Nov. 3, 2016).
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¶6 Susnjar testified that respondent had previously agreed to take Stelazine (trifluoperazine),
Haldol (haloperidol), Benadryl (diphenhydramine), and lorazepam. When he took these
medications, his symptoms improved. He was able to plan and discuss his legal and health
situations. However, he eventually stopped taking the medications due to his preference for
“white” Stelazine. Susnjar explained that the EMHC offered only “purple” Stelazine. Beyond
the color, the medications were the same. After respondent stopped taking his medications,
his symptoms returned.
¶7 To treat respondent’s mood and psychosis, Susnjar sought to administer specified doses
of trifluoperazine, risperidone, quetiapine, and aripiprazole. Susnjar testified that the side
effects of the medications included neuroleptic malignant syndrome, involuntary movements,
lower blood pressure, sedation, muscle rigidity, tardive dyskinesia, diabetes, weight gain, and
cataracts. The primary benefits of the medications were that respondent would become calm
and better able to express himself and make decisions.
¶8 Susnjar also petitioned for the administration of five alternative medications: haloperidol,
fluphenazine, lorazepam, diphenhydramine, and benztropine. She testified that haloperidol
and fluphenazine were alternative psychotropic medications for the treatment of psychosis
and delirium and that they involved similar side effects and benefits as the primary
psychotropic medications. Lorazepam would be used if necessary to treat anxiety; the
potential side effects were sedation and addiction. Finally, diphenhydramine and benztropine
were used to treat the side effects from the psychotropic medications. The risks included
weight gain, confusion, dry mouth, constipation, and difficulty urinating.
¶9 Susnjar also testified at length about respondent’s kidney disease and her request for
hemodialysis treatments. She explained that respondent was admitted to Sherman Hospital
for renal failure in April 2015. When respondent was discharged in May 2015, his treating
nephrologist diagnosed him with end-stage kidney failure and recommended that he undergo
hemodialysis treatments three times per week. Respondent initially received 18 hemodialysis
treatments without incident, but he later began refusing the treatments. These refusals
happened around the same time that respondent began refusing to take the psychotropic
medications. Susnjar testified that she had repeatedly discussed with respondent the status of
his kidneys and the need for hemodialysis, but respondent insisted that it was not necessary.
Based on these facts, Susnjar opined that respondent’s mental illness was directly related to
his refusal to undergo hemodialysis. Although Susnjar refrained from speculating on a
specific time frame, she opined that respondent would eventually die if he did not receive
hemodialysis. Susnjar further opined that the hemodialysis was necessary for the safe and
effective administration of the psychotropic medications, because respondent’s kidneys could
not adequately filter the chemicals from his blood. Susnjar cautioned that, without
hemodialysis, the medications could cause a toxic accumulation that could lead to a coma.
¶ 10 On cross-examination, respondent’s trial counsel asked Susnjar whether she could safely
and effectively administer the psychotropic medications if respondent was not receiving
hemodialysis. Susnjar answered that she might be compelled to administer the medications in
certain limited circumstances, such as if respondent became violent, but that she would not
otherwise administer the medications unless she knew that respondent would be undergoing
regular hemodialysis.
¶ 11 In rendering its decision, the trial court acknowledged the potential risks involved with
the psychotropic medications, but it found that those risks were outweighed by the benefit of
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helping respondent manage his psychosis. The trial court noted Susnjar’s testimony that she
could not safely and effectively administer the psychotropic medications without the
hemodialysis. It accordingly granted the petition, authorizing the administration of each of
the requested medications, as well as the hemodialysis, for up to 90 days.
¶ 12 On September 17, 2015, respondent’s trial counsel filed a motion to reconsider. The trial
court entered an order denying the motion on October 16, 2015. Respondent timely appeals.
¶ 13 II. ANALYSIS
¶ 14 This appeal centers on whether the Mental Health Code was an appropriate vehicle for
the State to obtain an order requiring respondent to undergo hemodialysis. Respondent raises
two arguments in support of his contention that the trial court erred by granting the State’s
petition. He first argues that the benefits of the psychotropic medication did not clearly and
convincingly outweigh the risk of significant damage to his kidneys and that in finding to the
contrary, the trial court improperly factored in his receiving hemodialysis treatments.
Respondent’s second argument is that the trial court was not authorized under section
2-107.1 of the Mental Health Code to order hemodialysis as an essential procedure for the
safe and effective administration of the psychotropic medication. Before addressing these
arguments, we must first discuss the issue of mootness.
¶ 15 Respondent acknowledges that, because more than 90 days have passed since the trial
court granted the petition, the trial court’s order is no longer effective and this appeal is
therefore moot. He argues, however, that exceptions to the mootness doctrine apply.
¶ 16 An appeal is considered moot where it presents no actual controversy or where it is
impossible for the reviewing court to grant effectual relief to the complaining party. In re
Jonathan P., 399 Ill. App. 3d 396, 400 (2010). Reviewing courts generally refrain from
considering moot questions. Id. However, there are three recognized exceptions to the
mootness doctrine: (1) the public-interest exception, which applies where the case presents a
question of public importance that will likely recur and the answer will guide public officers
in the performance of their duties; (2) the capable-of-repetition exception, which applies to
cases involving events of short duration that are capable of repetition, yet evading review;
and (3) the collateral-consequences exception, which applies where the answer could have
consequences for a party in some future proceedings. In re Donald L., 2014 IL App (2d)
130044, ¶ 19. Although there is no per se exception to the mootness doctrine, most appeals in
mental health cases fall within one of these established exceptions. Id.¶ 17 Here, respondent argues that the capable-of-repetition and public-interest exceptions
apply. The State disagrees, arguing that this appeal presents a straightforward question of the
sufficiency of the evidence rather than a question of statutory interpretation or statutory
compliance. We agree with respondent. First, given respondent’s mental health history and
end-stage kidney failure, it is likely that he will be subjected to a petition with similar
requests in the future. See In re Alfred H.H., 233 Ill. 2d 345, 360 (2009) (holding that the
capable-of-repetition exception applies where there is a substantial likelihood that resolution
of an issue will have some bearing on a similar issue involving the same respondent in a
subsequent case). Second, cases involving the tests and procedures authorized under the
Mental Health Code have not specifically addressed whether a procedure for the treatment of
a physical health condition (such as kidney failure) can be ordered pursuant to section
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2-107.1. We therefore hold that the capable-of-repetition and public-interest exceptions to the
mootness doctrine apply in this case.
¶ 18 Turning to the merits, section 2-107.1 of the Mental Health Code “embodies this State’s
significant parens patriae interest in providing for persons who, while suffering from a
serious mental illness or development disability, lack the capacity to make reasoned
decisions concerning their need for medication.” In re C.E., 161 Ill. 2d 200, 217 (1994).
However, the forced administration of psychotropic medication involves a severe
interference with a person’s liberty. In re Robert S., 213 Ill. 2d 30, 46 (2004). The Mental
Health Code therefore provides safeguards to protect mental health patients from the misuse
of psychotropic medication by medical staff for purposes other than treating mental illness.
In re Larry B., 394 Ill. App. 3d 470, 474 (2009). Pursuant to section 2-107.1(a-5)(4), the
forced administration of psychotropic medication is authorized only if the trial court finds
clear and convincing evidence regarding each of the following elements:
“(A) That the recipient has a serious mental illness or developmental disability.
(B) That because of said mental illness or developmental disability, the recipient
currently exhibits any one of the following: (i) deterioration of his or her ability to
function, as compared to the recipient’s ability to function prior to the current onset of
symptoms of the mental illness or disability for which treatment is presently sought,
(ii) suffering, or (iii) threatening behavior.
(C) That the illness or disability has existed for a period marked by the continuing
presence of the symptoms set forth in item (B) of this subdivision (4) or the repeated
episodic occurrence of these symptoms.
(D) That the benefits of the treatment outweigh the harm.
(E) That the recipient lacks the capacity to make a reasoned decision about the
treatment.
(F) That other less restrictive services have been explored and found
inappropriate.
(G) If the petition seeks authorization for testing and other procedures, that such
testing and procedures are essential for the safe and effective administration of the
treatment.” 405 ILCS 5/2-107.1(a-5)(4) (West 2014).
¶ 19 We note at the outset that respondent challenges the trial court’s findings pertaining only
to subsections (D) and (G). He has not challenged any of the findings regarding his mental
fitness, nor has he challenged his diagnosis of end-stage kidney failure. Respondent also
concedes that a patient with end-stage kidney failure will die without artificial support and
treatment such as hemodialysis. He nonetheless maintains that the trial court’s order
improperly infringed on his substantial liberty interest to refuse psychotropic medication and
hemodialysis. See C.E., 161 Ill. 2d at 216.
¶ 20 We must also address the parties’ disagreement over the applicable standard of review.
As noted, the State asserts that this is a “routine sufficiency of the evidence question.” This is
supported to a certain extent by respondent’s brief, in which he labels his arguments as
challenges to whether the State satisfied by clear and convincing evidence the statutory
factors in question. The State accordingly argues that we should not reverse the trial court’s
order unless it is against the manifest weight of the evidence. See In re Vanessa K., 2011 IL
App (3d) 100545, ¶ 28 (“This court will not reverse a trial court’s order permitting the
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involuntary administration of psychotropic medication unless it is against the manifest
weight of the evidence.”). In his reply brief, respondent acknowledges the manner in which
he has framed his arguments, but he argues that this case concerns an issue of statutory
compliance and that we should therefore review the trial court’s order de novo. See Jonathan
P., 399 Ill. App. 3d at 401 (“Whether the order complied with the [Mental Health] Code
presents a question of law, which we review de novo.”).
¶ 21 As we have discussed, the primary issue respondent raises is whether the Mental Health
Code was an appropriate vehicle for the State to ensure that he would undergo hemodialysis.
Respondent argues that the trial court improperly factored in the hemodialysis in weighing
the benefits and harm of the psychotropic medication and that the trial court lacked
authorization to order the hemodialysis. The facts surrounding these issues are not in dispute;
they are questions purely of law, and the appropriate standard of review is de novo. See In re
Alaka W., 379 Ill. App. 3d 251, 259 (2008). Once these issues have been resolved, we will
consider whether the trial court’s order is against the manifest weight of the evidence.
¶ 22 Respondent first argues that the State failed to prove by clear and convincing evidence
that the benefits of the psychotropic medication outweighed the harm. See 405 ILCS
5/2-107.1(a-5)(4)(D) (West 2014). His overarching argument is that, absent the hemodialysis,
the benefits of the medication did not outweigh the risk of significant damage to his kidneys.
This is based on Susnjar’s admission that she could not safely administer the medication
without knowing that respondent would receive regular hemodialysis, due to the toxic
accumulation of chemicals that could otherwise occur in his blood. Respondent concedes in
his reply brief that the trial court was properly informed of the benefits and harm, but he
asserts that its decision was “based on a contingency that exceeded the Mental Health Code
[s]ection 2-107.1 authority.” We disagree.
¶ 23 We do not believe that the trial court erred by factoring the hemodialysis into its
consideration of whether the benefits of the psychotropic medication outweighed the harm. It
is foreseeable that a mental health patient in need of psychotropic medication would be
suffering from a physical health condition. It is also foreseeable that the negative effects from
a respondent’s physical health condition would be exacerbated by psychotropic medication.
See Robert S., 213 Ill. 2d at 50 (“Suffice it to say that the involuntary administration of
psychotropic drugs may have a profound and sometimes irreversible effect upon a recipient’s
personality and physical health.”). We do not believe that a trial court under these
circumstances is bound to consider the benefits and harm of psychotropic medication in a
vacuum, without any regard for the absence or presence of treatment for a respondent’s
physical health condition. Rather, we believe that the better approach is for a trial court to
consider the totality of the evidence in rendering its conclusion. Here, the trial court heard
evidence that hemodialysis would offset a significant harm that the psychotropic medication
would cause. In our view, it would be untenable to hold that this type of evidence may not be
factored into a trial court’s consideration of the benefits and harm of psychotropic
medication.
¶ 24 We find guidance on this issue from In re Val Q., 396 Ill. App. 3d 155 (2009). The
respondent in that case had an abnormal QT interval, meaning her heart took an abnormal
amount of time to reset itself between beats. The testifying physician acknowledged that the
requested medication had the potential to exacerbate the abnormal QT interval, which could
increase the risk of arrhythmia or heart attack. The physician stated that he would begin
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involuntary treatment only after consulting with the respondent’s primary-care physician.
The trial court authorized the involuntary treatment with the “ ‘initial caveat’ ” that the
physician first seek consultation to determine the risks posed by the treatment. Id. at 158-59.
This court reversed the trial court, holding that information regarding the potential risks to
the respondent’s heart was necessary before the trial court could engage in any meaningful
review of the risks and benefits of the proposed treatment plan. Id. at 163.
¶ 25 Unlike the physician in Val Q., Susnjar performed the consultation necessary to inform
the trial court of the risks and benefits associated with her proposed treatment plan. Susnjar
testified that she had consulted with respondent’s nephrologist to find the proper balance of
psychotropic medications to maximize the likelihood of respondent’s receiving the
hemodialysis. She explained that respondent had been voluntarily receiving the hemodialysis
when he was taking psychotropic medication; he began refusing the hemodialysis only after
he began refusing to take the medication. The “initial caveat” discussed by Susnjar was that,
as per her consultation with the nephrologist, so long as respondent was receiving the
treatment for his kidneys, the benefits of the medication would outweigh the risks. Susnjar
further testified that the involuntary administration of psychotropic medication would serve
the dual purposes of improving respondent’s mental health and increasing the likelihood of
his receiving treatment for his debilitating physical condition. Under these circumstances, we
find no fault with the trial court’s consideration of whether respondent would be receiving
hemodialysis or its conclusion that, with the hemodialysis, the benefits of the requested
medications outweighed the harm.
¶ 26 As a corollary to his overarching argument, respondent asserts that Susnjar failed to
adequately define an administration plan for the requested medications and that she therefore
failed to meaningfully weigh the benefits and harm of her proposed treatment plan. See In re
Williams, 305 Ill. App. 3d 506, 512 (1999) (“An order allowing the use of psychotropic drugs
cannot be based upon a new regimen so poorly defined that the expert could not have
meaningfully weighed the benefits and harm involved.”). We disagree. The petition and
Susnjar’s testimony provided enough details to show that she had meaningfully weighed the
benefits and harm involved with the requested medications. Moreover, the trial court
commented that it “[did] not take lightly the potential serious side effects associated with the
medication” but stressed Susnjar’s testimony that the medication would help respondent
manage his delusions, hallucinations, suffering, and threatening behavior. In light of our
holding that the trial court properly considered respondent’s receiving hemodialysis, we do
not believe that its finding that the benefits of the psychotropic medication outweighed the
harm is against the manifest weight of the evidence.
¶ 27 Respondent’s second argument is that the trial court was not authorized to order
hemodialysis as a procedure for the safe and effective administration of the psychotropic
medication. See 405 ILCS 5/2-107.1(a-5)(4)(G) (West 2014) (authorizing the trial court to
grant a petition for “testing and other procedures” that are “essential for the safe and effective
administration of the treatment”). Respondent acknowledges that section 2-107.1 provides
the authority to order blood testing to ensure the safe administration of psychotropic
medication where the statute’s requirements are met by clear and convincing evidence. In re
Floyd, 274 Ill. App. 3d 855, 863 (1995); see also In re Jill R., 336 Ill. App. 3d 956, 964
(2003) (“Under the doctrine of parens patriae, courts have the implied authority to order
periodic blood testing to ensure the safe administration of psychotropic drugs, provided the
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requirements of section 2-107.1 of the [Mental Health] Code are met by clear and convincing
evidence.”). Respondent argues, however, that the statute does not allow for “invasive”
procedures such as hemodialysis.
¶ 28 In Floyd, the appellate court held that section 2-107.1 would be rendered meaningless if a
trial court was unable to order monitoring of medication levels in a respondent’s blood.
Floyd, 274 Ill. App. 3d at 863. The court commented that a doctor who prescribed
psychotropic medication could be found guilty of malpractice if the levels of the drugs were
not properly monitored and the respondent suffered toxic side effects. Id. This court has since
held that specific evidence is needed for trial courts to determine which tests are essential for
the safe and effective administration of treatment. Donald L., 2014 IL App (2d) 130044, ¶ 26
(concluding that trial courts may not allow doctors to administer unspecified tests at their
own discretion). Here, Susnjar satisfied the requirement from Donald L. insofar as it pertains
to the “other procedures” authorized under section 2-107.1. She testified that, without the
hemodialysis, respondent’s end-stage kidney failure would render him susceptible to a toxic
accumulation of chemicals from the psychotropic medication. We believe that the same
rationale for finding authorization to order blood testing in Floyd allows us to find
authorization to order hemodialysis in this case.
¶ 29 The evidence here reflected that respondent’s mental illness symptoms returned after he
refused to take psychotropic medication. He became delusional, angry, and unable to
converse. He refused to acknowledge the status of his kidneys and he denied that he needed
hemodialysis. Susnjar was therefore faced with the choice of (1) taking no action, (2)
petitioning for only the involuntary administration of psychotropic medication, or (3)
petitioning for hemodialysis in conjunction with the involuntary administration of
psychotropic medication. But respondent acknowledges that a patient diagnosed with
end-stage kidney failure will die without artificial support and treatment such as
hemodialysis. Moreover, because respondent had been found unfit to stand trial on a robbery
charge, his commitment to the mental health system was an indication of his lack of
decisional capacity. See Larry B., 394 Ill. App. 3d at 476. We therefore believe that Susnjar
would have been derelict in her duties had she stood idly by as respondent’s mental and
physical health simultaneously deteriorated. Likewise, Susnjar could have been found guilty
of malpractice if she had administered the psychotropic medication without an assurance that
respondent would undergo hemodialysis. Given respondent’s dire physical health, we cannot
fault Susnjar for choosing the third option.
¶ 30 Respondent maintains that the trial court improperly intruded into his therapeutic medical
decisions for the purpose of administering psychotropic medication. He argues that, although
Susnjar was unable to determine whether he had executed a power of attorney for health care
or a declaration under the Mental Health Treatment Preference Declaration Act (755 ILCS
43/1 et seq. (West 2014)), the Mental Health Code was not the proper vehicle for ensuring
that he would undergo hemodialysis. Respondent asserts that the proper course of action
would have been to have the trial court declare him incompetent and appoint either a
personal guardian under the Probate Act of 1975 (755 ILCS 5/11a-17 (West 2014)), or a
surrogate under the Health Care Surrogate Act (755 ILCS 40/20 (West 2014)), who would
then have the authority to consent to respondent’s receiving the hemodialysis. We disagree.
Even if one of these alternative vehicles had been used, and assuming that the individual
granted such authority would have consented to hemodialysis on respondent’s behalf, Susnjar
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would not necessarily have been adequately assured that she could safely and effectively
administer psychotropic medication. We see no reason why Susnjar should not have persisted
with the section 2-107.1 petition as a means of guaranteeing that respondent would receive
hemodialysis.
¶ 31 One final case guides our analysis. In In re Mary Ann P., 202 Ill. 2d 393, 406 (2002), our
supreme court rejected an argument that section 2-107.1 impliedly allows for the selective
authorization of only certain of the requested medications. The court reasoned that such an
interpretation would permit the jury to substitute a treatment different from that
recommended by the testifying physician and set forth in the petition. Id. Thus, where the
recommended treatment consists of multiple medications, with some to be administered
alternatively, others in combination, and others as needed to counter side effects, “it is only
this treatment, in its entirety, that may be authorized.” Id. at 405-06.
¶ 32 We believe that, pursuant to Mary Ann P., the trial court in this case was precluded from
authorizing anything short of the treatment plan recommended by Susnjar, including the
hemodialysis. See Jonathan P., 399 Ill. App. 3d at 404 (“While the rule in Mary Ann P. does
not create an absolute bar on a court’s approval of fewer than all of the medications listed in
a petition, it requires that any variance from the petition be made at the behest of the treating
physician.”). Contrary to respondent’s repeated suggestions, his mental and physical health
conditions were inextricably linked. Out of necessity, Susnjar’s treatment plan addressed
both of these conditions.
¶ 33 Before concluding, we feel compelled to address respondent’s assertion that, by reversing
the trial court’s order, we would “discourage inappropriate attempts to treat medical
conditions in mental health proceedings.” Respondent would have us limit the “testing and
other procedures” authorized under section 2-107.1 to those deemed noninvasive. However,
the State counters by noting that the Mental Health Code does not contain any language
limiting the “testing and other procedures” authorized under section 2-107.1 to noninvasive.
The State’s point is well taken. While we caution that a section 2-107.1 petition should not be
used as an end-around to obtain authority for testing or other procedures to treat a
respondent’s physical health condition, we believe that the statute includes the necessary
safeguards. Namely, based on the plain language of section 2-107.1, the State must prove by
clear and convincing evidence that the requested testing or other procedures are “essential for
the safe and effective administration of the treatment.” 405 ILCS 5/2-107.1(a-5)(4)(G) (West
2014). The trial court here ordered the hemodialysis treatments on the basis of its finding that
the State satisfied this burden. We do not believe that this finding is against the manifest
weight of the evidence.
¶ 34 III. CONCLUSION
¶ 35 The judgment of the circuit court of Kane County is affirmed.
¶ 36 Affirmed.
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