¶ 18 Our supreme court has held section 3-816(a) is directory and, as such, noncompliance is not grounds for reversal. In re Rita P., 2014 IL 115798, ¶ 68, 10 N.E.3d 854. According to the court, section 3-816(a) is not mandatory in the absence of statutorily prescribed consequences for noncompliance or where the rights the statute was designed to protect would not generally be injured by a directory reading. Rita P., 2014 IL 115798, ¶ 44, 10 N.E.3d 854. The court concluded "no reason [exists] to conclude a respondent's appeal rights or liberty interests will generally be injured through a directory reading of section 3-816(a)."

Alfred H.H. , 233 Ill.2d at 355, 331 Ill.Dec. 1, 910 N.E.2d 74 ; In re James W. , 2014 IL App (5th) 110495, ¶ 21, 381 Ill.Dec. 786, 11 N.E.3d 417. The exception is narrowly construed and applies only where a clear showing is made of each criterion. Alfred H.H. , 233 Ill.2d at 355-56, 331 Ill.Dec. 1, 910 N.E.2d 74. Case-specific inquiries, such as the sufficiency of the evidence, do not implicate issues of a public nature. In re Rita P. , 2014 IL 115798, ¶ 36, 381 Ill.Dec. 445, 10 N.E.3d 854 ; Alfred H.H. , 233 Ill.2d at 356, 331 Ill.Dec. 1, 910 N.E.2d 74. However, questions regarding compliance with the Code's procedures "involve matters of substantial public concern." (Internal quotation marks omitted.)

Id. ¶ 16.¶ 4 The Illinois Supreme Court then entered a supervisory order directing us to vacate that decision and reconsider it in light of In re Rita P., 2014 IL 115798. In re Latoya C., No. 116555 (Ill. Sept. 24, 2014).

However, the presumption of a directory reading will be overcome, and the command will be read as mandatory if either one of the following two conditions is present: (1) when there is negative language in the statute prohibiting further action or indicating a specific consequence in the case of noncompliance or (2) when the right the statute is designed to protect would generally be injured if a directory reading was given to the command. Id. ¶ 17; In re Rita P., 2014 IL 115798, ¶ 44, 381 Ill.Dec. 445, 10 N.E.3d 854. ¶ 21 In the present case, after having reviewed the statutory language, we find that the procedural command contained in section 2–10.1 of the Act—that DCFS "shall" file a service plan with the court within 45 days after the minor's placement in shelter care—is directory and not mandatory.

In re Robert S. , 213 Ill. 2d 30, 46, 289 Ill.Dec. 648, 820 N.E.2d 424 (2004) (quoting In re Mary Ann P. , 202 Ill. 2d 393, 402, 269 Ill.Dec. 440, 781 N.E.2d 237 (2002) ); see also In re Rita P. , 2014 IL 115798, ¶ 36, 381 Ill.Dec. 445, 10 N.E.3d 854 ("resolution of this issue will affect the procedures that must be followed in proceedings under the Mental Health Code, which this court has already acknowledged are ‘matters of a public nature and of substantial public concern’ " (quoting In re Mary Ann P. , 202 Ill. 2d at 402, 269 Ill.Dec. 440, 781 N.E.2d 237 )); In re Nicholas L. , 407 Ill. App. 3d 1061, 1071, 348 Ill.Dec. 431, 944 N.E.2d 384 (2011) ("questions about compliance with the Code's procedures involve matters of substantial public concern" (internal quotation marks omitted)). ¶ 56 Regarding the second factor, "the need for an authoritative determination of the question, we consider the state of the law as it relates to the moot question."

¶ 28 The collateral-consequences exception applies to mental-health cases and is decided on a case-by-case basis. In re Rita P., 2014 IL 115798, ¶ 31, 10 N.E.3d 854 (citing Alfred H.H., 233 Ill. 2d at 362, 910 N.E.2d at 84). "Under this exception, where collateral consequences survive the expiration or cessation of a court order that are likely to be redressed by a favorable judicial determination, appellate review is permissible.

The present action and a potential future action must have a substantial enough relation that the resolution of the issue in the present case would have a bearing on a similar issue presented in a future case involving the defendant. See In re Val Q., 396 Ill.App.3d 155, 160, 336 Ill.Dec. 51, 919 N.E.2d 976 (2009) (citing Alfred H.H., 233 Ill.2d at 360, 331 Ill.Dec. 1, 910 N.E.2d 74 ), overruled on other grounds, In re Rita P., 2014 IL 115798, ¶¶ 33–34, 381 Ill.Dec. 445, 10 N.E.3d 854. In cases where the defendant challenges the specific facts that were established during the hearing, the exception generally does not apply, because those facts would necessarily be different in any future hearing and would have no bearing on similar issues presented in subsequent cases.

Whether a court's mootness determination is correct is a legal issue subject to de novo review. In re Rita P., 2014 IL 115798, ¶ 30.

When resolving a question of statutory construction to determining whether a statutory command is mandatory or directory, however, we review de novo. In re Rita P., 2014 IL 115798, ¶ 43.

" ‘If such [written] notice is not given, then the State cannot establish that a respondent lacks the capacity to make a "reasoned decision" about treatment, because the written notice forms the basis upon which such a decision can be made.’ " In re Wilma T. , 2018 IL App (3d) 170155, ¶ 23, 422 Ill.Dec. 227, 103 N.E.3d 359 (quoting In re Katarzyna G. , 2013 IL App (2d) 120807, ¶¶ 16-17, 374 Ill.Dec. 446, 995 N.E.2d 585 ); see also Tiffany W. , 2012 IL App (1st) 102492-B, ¶ 22, 365 Ill.Dec. 84, 977 N.E.2d 1183 ; In re Linda K. , 407 Ill. App. 3d 1146, 1153, 350 Ill.Dec. 380, 948 N.E.2d 660 (2011), overruled on other grounds , In re Rita P. , 2014 IL 115798, ¶¶ 33-34, 381 Ill.Dec. 445, 10 N.E.3d 854. Although a 105-page packet of medication handouts was filed in the record (the first page of which is signed by someone who claimed to have given the materials to Marcus), no one testified at trial that this packet was provided to Marcus.