## Facts

- Betty Gregorovich was a 21-year-old woman who became the subject of proceedings for involuntary judicial admission under the Illinois Mental Health and Developmental Disabilities Code.
- In the month before her hospitalization, her behavior toward her mother became increasingly aggressive.
- Early in that month, Gregorovich assaulted her mother, scratching her mother’s hand; the scratches left marks that took about three weeks to heal.
- In the incident immediately leading to hospitalization, Gregorovich’s mother asked her to lower the television volume.
- Gregorovich responded by cutting the television’s power cord and then cutting the power cords of the lamps in the home.
- Gregorovich then turned the scissors toward her mother while her mother was nearby, prompting her mother to call the police.
- Following the incident, Gregorovich was taken to a hospital, where she was examined by two psychiatrists and a mental-health worker.
- At the commitment hearing, hospital professionals testified that Gregorovich suffered from paranoid schizophrenia and displayed symptoms including hostility toward staff, poor hygiene, auditory hallucinations, delusions, and the belief that she could read and control other people’s minds.
- The professionals recommended continued inpatient treatment even though Gregorovich had not harmed herself or others during her hospital stay.
- One psychiatrist testified that Gregorovich had expressed a desire to kill her mother and that there was a possibility of future harm.
- The circuit court of Cook County found Gregorovich to be a “person subject to involuntary admission” and entered an order for involuntary hospitalization.
- Gregorovich appealed, arguing the evidence was insufficient to justify involuntary admission.

## Issues

1. Whether the Illinois Mental Health and Developmental Disabilities Code requires proof that a respondent is a “definite danger” to herself or others before a court may order involuntary admission.
2. Whether the evidence presented at the hearing was sufficient (under the clear-and-convincing standard) to support the trial court’s finding that Gregorovich was a person subject to involuntary admission.

## Decision

- The appellate court affirmed the order of involuntary admission.
- The court rejected the argument that the State had to prove Gregorovich was a “definite danger” before commitment could be ordered.
- Based on the recent aggressive conduct toward her mother, the scissors incident, and the medical testimony about paranoid schizophrenia and risk of harm, the court held the trial court’s finding was supported by the evidence.

## Legal Principles

- In Illinois civil-commitment proceedings, the State must prove by clear and convincing evidence that the respondent meets the statutory definition of a person subject to involuntary admission.
- The State is not required to show the respondent is a “definite danger” to herself or others; courts need not wait until physical injury occurs before ordering hospitalization.
- Recent acts of aggression or threats, considered with clinical testimony about severe mental illness and the likelihood of harm if untreated, can support a finding that involuntary inpatient treatment is warranted.

## Conclusion

Matter of Gregorovich affirmed an involuntary admission order where the respondent’s recent violence and threatening conduct toward her mother, combined with professional testimony diagnosing paranoid schizophrenia and describing a risk of future harm, provided sufficient proof under the Mental Health and Developmental Disabilities Code even without showing that she was a definite or already-injuring danger.


Matter of Gregorovich, 89 Ill. App. 3d 528, 44 Ill. Dec. 615, 411 N.E.2d 981 (1980)