It was an error of law, and so an abuse of discretion, for the Orphans’ Court to deny a third petition for a guardian of the person when there was evidence that the electroconvulsive treatments (“ECT”) that were administered to the incapacitated person (IP) with the consent of the emergency guardian and temporary guardian appointed in accordance with the first two petitions were effective but the IP’s mental illnesses had returned, and so there was a new emergency allowing the use of the emergency guardianship procedure, as well as evidence that the IP would suffer irreparable harm without additional ECT. In re: L.L.H., 1420 MDA 2025 (Pa. Super. 11/14/2025) (non-precedential).