Generally, a trial court's order permitting the involuntary administration of psychotropic medication will not be reversed unless it is against the manifest weight of the evidence. In re Louis S., 361 Ill. App. 3d 774, 779, 838 N.E.2d 226, 231 (2005). "A judgment will be considered against the manifest weight of the evidence `only when an opposite conclusion is apparent or when the findings appear to be unreasonable, arbitrary, or not based on evidence.'"

¶ 38 In cases involving the involuntary administration of psychotropic medication, courts reviewing the sufficiency of the evidence "will not overturn the trial court's ruling unless it is against the manifest weight of the evidence." In re Louis S., 361 Ill. App. 3d 774, 779, 838 N.E.2d 226, 231 (2005). Under section 2-107.1, the State must show by clear and convincing evidence:

In re Robert S., 213 Ill. 2d 30, 46, 820 N.E.2d 424, 434 (2004), quoting In re Mary Ann P., 202 Ill. 2d 393, 402, 781 N.E.2d 237, 243 (2002). This court has already addressed similar questions regarding compliance with section 2-102(a-5) (see A.W., 381 Ill. App. 3d at 956-57, 887 N.E.2d at 837; In re Louis S., 361 Ill. App. 3d 774, 780, 838 N.E.2d 226, 232 (2005)), and thus this issue's recurrence indicates both (1) a need still exists for guidance in this area and (2) the likeliness of future recurrence in other mental-health cases. Respondent's second argument shows a need for clarification of a prior holding, and thus it too presents a public matter that needs addressed and is likely to recur in future mental-health cases.

The State is required to present clear and convincing evidence of compliance with section 2-102(a-5). Laura H., 404 Ill. App. 3d at 290 (citing In re Louis S., 361 Ill. App. 3d 774, 779-80 (2005)). The rationale underlying the requirements of section 2-102 (a-5) is to not only ensure that a respondent is fully informed, but also "to ensure that a respondent's due process rights are met and protected."

"If the services include the administration of authorized involuntary treatment, the physician or the physician's designee shall advise the recipient, in writing, of the side effects, risks, and benefits of the treatment, as well as alternatives to the proposed treatment, to the extent such advice is consistent with the recipient's ability to understand the information communicated." In In re Louis S., 361 Ill. App. 3d 774, 780, 838 N.E.2d 226, 232 (2005), this court held that the State must present clear and convincing evidence that the respondent received written notification of the side effects, risks, and benefits of the treatment, as well as alternatives to the proposed treatment, as required by section 2-102(a-5) of the Code. In so holding, we noted that (1) verbal notification is insufficient to ensure a respondent's due-process rights, (2) "the right to written notification is not subject to a harmless-error analysis," and (3) strict compliance with the procedural safeguards of the Code is necessary to protect the liberty interests involved.

The court may only authorize the involuntary administration of psychotropic medication if it finds that the State has met its burden of proving all of these factors. In re Louis S. , 361 Ill. App. 3d 774, 779, 297 Ill.Dec. 739, 838 N.E.2d 226 (2005). ¶ 23 If the court does authorize involuntary medication, it must specify in its order the medications authorized, the ranges of dosages authorized for each medication, and the names of the individuals authorized to administer the treatment.

" 'The trial court must find evidence of each of the elements to authorize the forced administration of psychotropic medication.' " In re Bobby F., 2012 IL App (5th) 110214, ¶ 16, 970 N.E.2d 25 (quoting In re Louis S., 361 Ill. App. 3d 774, 779, 838 N.E.2d 226, 232 (2005)).¶ 25 Our supreme court has defined clear and convincing evidence as the quantum of proof that leaves no reasonable doubt in the mind of the fact finder regarding the truth of the proposition in question.

¶ 20 Before a respondent can make a reasoned decision about medication, she first must be advised as to the risks and benefits of the proposed course of treatment. In re Louis S., 361 Ill. App. 3d 774, 780, 838 N.E.2d 226, 232 (2005) (quoting John R., 339 Ill. App. 3d at 783, 792 N.E.2d at 354). To that end, section 2-102(a-5) of the Mental Health Code imposes the following additional requirements:

“The trial court must find evidence of each of the elements to authorize the forced administration of psychotropic medication.” In re Louis S., 361 Ill.App.3d 774, 779, 297 Ill.Dec. 739, 838 N.E.2d 226 (2005). ¶ 17 The respondent argues that the State failed to provide clear and convincing evidence that the respondent lacked the decisional capacity to make a reasoned decision about the proposed treatment (405 ILCS 5/2–107.1(a–5)(4)(E) (West 2010)) because the State failed to prove that it had complied with section 2–102(a–5) of the Code (405 ILCS 5/2–102(a–5) (West 2010)).

"The trial court must find evidence of each of the elements to authorize the forced administration of psychotropic medication." In re Louis S., 361 Ill. App. 3d 774, 779 (2005). ¶ 17 The respondent argues that the State failed to provide clear and convincing evidence that the respondent lacked the decisional capacity to make a reasoned decision about the proposed treatment (405 ILCS 5/2-107.1(a-5)(4)(E) (West 2010)) because the State failed to prove that it had complied with section 2-102(a-5) of the Code (405 ILCS 5/2-102(a-5) (West 2010)).