¶ 14 Pursuant to the fourteenth amendment's due process clause, persons who suffer from mental illness have constitutionally protected liberty interests that permit them to refuse the involuntary administration of psychotropic medications. In re C.E., 161 Ill.2d 200, 213, 204 Ill.Dec. 121, 641 N.E.2d 345 (1994); In re Williams, 305 Ill.App.3d 506, 509, 238 Ill.Dec. 628, 712 N.E.2d 350 (1999). Because involuntary mental health services, including the involuntary administration of psychotropic drugs, involve a massive curtailment of liberty (In re Robert S., 213 Ill.2d at 46, 289 Ill.Dec. 648, 820 N.E.2d 424), Illinois courts have repeatedly recognized the importance of “the procedures enacted by our legislature to ensure that Illinois citizens are not subjected to such services improperly.”

As the respondent's liberty interest is at stake, any failure by the trial court to follow the "strict letter of the statute" requires reversal by the reviewing court. In re Williams, 305 Ill. App. 3d 506, 511 (1999). Reversal is required even if the respondent fails to show any actual prejudice resulting from the error.

¶ 14 Pursuant to the fourteenth amendment's due process clause, persons who suffer from mental illness have constitutionally protected liberty interests that permit them to refuse the involuntary administration of psychotropic medications. In re C.E., 161 Ill. 2d 200, 213 (1994); In re Williams, 305 Ill. App. 3d 506, 509 (1999). Because involuntary mental health services, including the involuntary administration of psychotropic drugs, involve a massive curtailment of liberty (In re Robert S., 213 Ill. 2d at 46), Illinois courts have repeatedly recognized the importance of "the procedures enacted by our legislature to ensure that Illinois citizens are not subjected to such services improperly."

"Persons who suffer from mental illness have constitutionally protected liberty interests that permit them to refuse involuntary *** administration of psychotropic medications [citation]." In re Williams, 305 Ill. App. 3d 506, 509 (1999). "Courts must scrutinize legislation that permits the involuntary administration of psychotropic medications to persons afflicted with mental illness, because of concerns about the substantially invasive nature of psychotropic substances, the significant side effects associated with those medications, and the recognition that psychotropic substances may be misused by medical personnel as a means of patient control rather than treatment."

Persons who suffer from mental illness have constitutionally protected liberty interests that permit them to refuse involuntary commitment and the administration of psychotropic medications. In re Williams, 305 Ill. App.3d 506, 509, 712 N.E.2d 350, 352 (1999). Any legislation that infringes upon these liberty interests must bear an important and substantial relationship to the State's interest in providing for mentally ill people who present a danger to themselves or others or who lack the capacity to make informed decisions concerning psychotropic medications.

Although treatment with psychotropic medication may involve the administration of a single drug (see, e.g., In re Miller, 301 Ill.App.3d 1060, 1065-66, 235 Ill.Dec. 531, 705 N.E.2d 144 (1998) ), treatment frequently involves the administration of several medications (see, e.g.,R.W., 332 Ill.App.3d at 903-04, 266 Ill.Dec. 762, 775 N.E.2d 602; In re Williams, 305 Ill.App.3d 506, 507-08, 238 Ill.Dec. 628, 712 N.E.2d 350 (1999); In re Barry B., 295 Ill.App.3d 1080, 1083, 230 Ill.Dec. 404, 693 N.E.2d 882 (1998); in rE perona, 294 ilL.app.3D 755, 767, 229 ilL.dec. 11, 690 N.E.2d 1058 (1998)). Nothing in the language of section 2-107.1 indicates that where the treatment involves more than one medication, the legislature intended the jury to parse the treatment and choose among the various medications.

Involuntary commitment affects very important liberty interests, and thus those seeking to keep an individual sa confined must strictly comply with procedural safeguards included within the Mental Health and Developmental Disabilities Code. In re Williams, 305 Ill. App. 3d 506, 509, 712 N.E.2d 350, 352 (1999). These safeguards are included within the Code to ensure that the mental health system does not become an oppressive tool rather than a means to serve the society in which we live.

Because the administration of any involuntary mental health services to an unwilling patient entails a " ‘massive curtailment of liberty’ " ( In re Barbara H. , 183 Ill. 2d at 496, 234 Ill.Dec. 215, 702 N.E.2d 555 (quoting Vitek v. Jones , 445 U.S. 480, 491, 100 S.Ct. 1254, 63 L.Ed.2d 552 (1980) )), "Illinois courts have required strict compliance with [the Mental Health] Code's procedural safeguards to insure that the mental health system does not become a tool to oppress rather than to serve society" ( 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).

¶ 16 Turning to the merits of the remaining arguments raised in respondent's appeal, she initially asserts several instances in which the circuit court purportedly failed to comply with the requirements of section 2-107.1(a-5)(4) of the Mental Health Code. Because the administration of any involuntary mental health services to an unwilling patient entails a" 'massive curtailment of liberty'" (In re Barbara H., 183 Ill.2d at 496 (quoting Vitek v. Jones, 445 U.S. 480, 491 (1980))), "Illinois courts have required strict compliance with [the Mental Health] Code's procedural safeguards to insure that the mental health system does not become a tool to oppress rather than to serve society" (In re Williams, 305 Ill.App.3d 506, 509 (1999)). "Noncompliance with statutory provisions of the [Mental Health Code] renders a judgment entered under such circumstances erroneous and of no effect."

tions between involuntarily administered medications. See, e.g. , Robert S. , 213 Ill. 2d at 52-53, 289 Ill.Dec. 648, 820 N.E.2d 424 (finding that a psychology intern was not qualified to perform an independent evaluation or give meaningful testimony in proceedings on a petition for the involuntary administration of psychotropic medications because "[o]nly a physician—such as a psychiatrist" has the "level of knowledge * * * necessary to safely prescribe medication, to fully recognize its beneficial effects as well as its adverse side effects, [and] to understand its interaction with other drugs " (emphasis added)); In re Dru G. , 369 Ill. App. 3d 650, 657-58, 308 Ill.Dec. 1, 860 N.E.2d 845 (2006) (following Robert S. and noting that psychologists "cannot give meaningful opinions on the possible harmful effects" of medication because they do not have the requisite knowledge concerning harmful side effects of individual drugs or "their interactions with other drugs " (emphasis added)); In re Williams , 305 Ill. App. 3d 506, 511, 238 Ill.Dec. 628, 712 N.E.2d 350 (1999) (finding that the State failed to prove that the benefits of treatment outweighed the harm where the expert's testimony was "general and vague" and the expert was not asked whether three of the medications he wanted to administer had any side effects "or whether there [were] potential complications posed by the interactions of these medications " (emphasis added)). Although these cases are not dispositive, they support our decision because they illustrate our concern with the significant harm that can result from drug interactions.