See Vojas v. K Mart Corp., 312 Ill. App. 3d 544, 549, 727 N.E.2d 397, 401 (2000); Aguinaga v. City of Chicago, 243 Ill. App. 3d 552, 575, 611 N.E.2d 1296, 1313 (1993). Nonetheless, we are compelled to address the other two issues because our position is divergent from cases in the Second District — In re Timothy H., 301 Ill. App. 3d 1008, 704 N.E.2d 943 (1998); In re Nancy M., 317 Ill. App. 3d 167, 739 N.E.2d 607 (2000); and In re Frances K., 322 Ill. App. 3d 203, 749 N.E.2d 1082 (2001). Like the Second District found in Timothy H. and Nancy M., we find that this case falls within the exception to the mootness doctrine.

Citing In re Nancy M., 317 Ill.App.3d 167, 250 Ill.Dec. 844, 739 N.E.2d 607 (2000), the appellate court held that the jury was required to specify in its verdict which medications were appropriate, and that the general verdict form "failed to show that the jury clearly intended to authorize the administration of all six medications listed in the trial court's subsequent written order." The dissenting justice disagreed, citing the reasons set forth in his dissent [202 Ill.2d 401] in In re Frances K., 322 Ill.App.3d 203, 211-13, 255 Ill.Dec. 600, 749 N.E.2d 1082 (2001) (Grometer, J., dissenting). In that case, the dissenting justice criticized Nancy M., stating that, "under the holding of Nancy M., the jury is, in effect, being asked to prescribe the medication and treatment" and that "[s]uch a requirement * * * goes far beyond the clear legislative scheme."

The involuntary administration of medication for mental health purposes involves fundamental liberty interests. In re Frances K., 322 Ill. App. 3d 203, 208 (2001). Further, the waiver rule is a limitation on parties and not on reviewing courts.

( In re Williams , 305 Ill. App. 3d 506, 509, 238 Ill.Dec. 628, 712 N.E.2d 350 (1999) ). "Noncompliance with statutory provisions of the [Mental Health Code] renders a judgment entered under such circumstances erroneous and of no effect." In re Frances K. , 322 Ill. App. 3d 203, 208, 255 Ill.Dec. 600, 749 N.E.2d 1082 (2001). Whether the order complied with the Mental Health Code presents a question of law, which we review de novo.

"Noncompliance with statutory provisions of the [Mental Health Code] renders a judgment entered under such circumstances erroneous and of no effect." In re Frances K., 322 Ill.App.3d 203, 208 (2001). Whether the order complied with the Mental Health Code presents a question of law, which we review de novo.

"However, under the plain error doctrine, this court may address a waived issue if the evidence is closely balanced or the error affects substantial rights." In re Frances K., 322 Ill. App. 3d 203, 208 (2001). Because "[f]undamental liberty interests are involved in the involuntary administration of medication for mental health purposes *** we will consider this issue on the merits.

The involuntary administration of medication for mental health purposes involves fundamental liberty interests. In re Frances K., 322 Ill.App.3d 203, 208, 255 Ill.Dec. 600, 749 N.E.2d 1082 (2001). Further, the waiver rule is a limitation on parties and not on reviewing courts.

The involuntary administration of medication for mental health purposes involves fundamental liberty interests. In re Frances K., 322 Ill. App. 3d 203, 208 (2001). Further, the waiver rule is a limitation on parties and not on reviewing courts.

In In re James S., we recently reversed the circuit court on this exact issue, noting that "in mental health cases, strict compliance with the Code is compelling because liberty interests are involved." In re James S., 388 Ill. App. 3d at 1107, citing In re Frances K., 322 Ill. App. 3d 203, 208 (2001). Thus, as in In re James S., because the circuit court failed to make written findings of fact and conclusions of law on the record as it was required to do under the Code, we reverse.

The phrase "same action" has been interpreted to mean that the same party will be subjected to the "same statutory provision" in the future ( A Minor, 127 Ill. 2d at 259) or to "similar orders" in the future ( In re Marie M., 374 Ill. App. 3d 913, 916 (2007)). See also In re Frances K., 322 Ill. App. 3d 203, 207 (2001) (where record indicated that respondent had a history of mental illness and hospitalization for such illness as recently as 2½ years prior to the hospitalization at issue on appeal, it was reasonable to expect that another petition may be filed against her in the future; thus, court addressed the merits of the appeal); In re Maher, 314 Ill. App. 3d 1088, 1097 (2000) (where respondent had a history of mental illness, and at least a brief history of prior involuntary hospitalization, it was reasonable to expect that the same action, i.e., involuntary admission, might be undertaken again). Indeed, our supreme court has specifically rejected the interpretation advocated by Alfred H.H.