Involuntary Commitment To Mental Health Center Moot; Illinois Supreme Court Reviews Mootness Exceptions

A trial court committed Alfred H.H. to the McFarland Mental Health Center in Illinois. Alfred appealed the commitment order. But he was discharged from McFarland while the appeal was pending, so the Illinois Appellate Court dismissed the appeal because it was moot.

Alfred appealed the dismissal to the Illinois Supreme Court. The supreme court rejected all five of Alfred’s arguments, and agreed the appeal was moot and was properly dismissed. Here is how the Illinois Supreme Court assessed the mootness arguments.

1. Alfred argued that the Illinois Mental Health Code gave him a right to appeal. But the court ruled that the Code only gave Alfred the right to appeal the commitment order “in the same manner as in other civil cases.” Alfred’s appeal, just like any other, was subject to the rules of mootness. “…[M]ootness is a factor that the courts will consider in determining whether it is appropriate to decide a given case.” The supreme court also ruled that there was not a case law exception to the mootness doctrine for commitment cases.

2. The supreme court ruled this case did not fall within the public interest exception to the mootness doctrine. The court agreed that “mental health cases do have the potential to deprive respondents of significant liberties … [but] that does nothing to examine the public nature of the issue presented within this appeal.” Alfred’s case, according to the court, involved the sufficiency of the evidence to commit him, and “[s]ufficiency of the evidence claims are inherently case-specific reviews that do not present the kinds of broad public interest issues” that satisfy this exception to the mootness doctrine.

3. Nor did this case fall within the exception of “capable of repetition yet evading review.” Alfred’s case was fact-specific, not a constitutional or statutory challenge. The court said there was “no clear indication of how a resolution of this [Alfred’s] issue could be of use to respondent [Alfred] in future litigation.”

4. The supreme court also stated that Alfred’s case did not invoke the collateral consequences exception. The court acknowledged that the collateral consequences exception can apply in mental health cases. But in Alfred’s case, the exception did not apply because “there is no collateral consequence that can be identified that could stem solely from the present adjudication. Every collateral consequence that can be identified already existed as a result of respondent’s previous adjudications and felony conviction.”

5. Alfred also argued the court should consider his appeal based on general policy considerations. Alfred claimed a right to appeal “because it is ‘therapeutic to provide procedural justice to mental health respondents.’” The supreme court rejected that argument, stating, “It is not appropriate for this court to create a new exception [to the mootness doctrine] simply because we believe that it may have tangential benefits to respondents in mental health cases.”

The whole opinion, In re Alfred H.H., No. 106616 (5/21/09), is available by clicking here.