In re R.L. (Aug. 20, 2025)

Case details
Country
United States
Jurisdiction
Illinois (IL)
Court
Illinois Supreme Court
Decided
Aug. 20, 2025
Disposition
Affirmed
Majority
Steigmann (Justice)
© 2025 Thomson Reuters. No claim to original U.S. Government Works.In re R.L.Appellate Court of Illinois, Fourth District. | August 20, 2025 | Not Reported in N.E. Rptr. | 2025 ILApp (4th) 241211-UDocument Detailsstandard Citation:In re R.L., 2025 IL App (4th) 241211-UAll Citations:Not Reported in N.E. Rptr., 2025 IL App (4th) 241211-U, 2025 WL2413284Search DetailsSearch Query:adv: (openai "artificial intelligence" chatgpt "google gemini" "westlawcocounsel" "large language model") (hallucinat! fake fictitious spuriousnonexistent "non-existent" "made up" imagined /p (gpt ai "artificialintelligence" chatgpt chaton perplexity openai copilot "google gemini""google bard" grok "mata v. avianca" claude llm llms)) (hallucinat! fakefictitious spurious nonexistent "non-existent" "made up" imagined) +3(precedent case "legal authority" "legal case") & DATE(aft 1/1/2023)Jurisdiction:IllinoisDelivery DetailsDate:September 5, 2025 at 11:09 AMDelivered By: Client ID:NOCLIENTIDOutlineORDER (p.1)All Citations (p.16)
In re R.L., Not Reported in N.E. Rptr. (2025)2025 IL App (4th) 241211-U © 2025 Thomson Reuters. No claim to original U.S. Government Works.12025 IL App (4th) 241211-UUNPUBLISHED OPINION. CHECK COURTRULES BEFORE CITING.NOTICE This Order was filed under SupremeCourt Rule 23 and is not precedent except in thelimited circumstances allowed under Rule 23(e)(1).Appellate Court of Illinois, Fourth District.IN RE R.L., a Minor(The People of the State ofIllinois, Petitioner-Appellee,v.Anezka L., Respondent-Appellant).NO. 4-24-1211|Filed August 20, 2025Appeal from the Circuit Court of Sangamon County,No. 21JA139, Honorable Karen S. Tharp, JudgePresiding.ORDERJUSTICE STEIGMANN delivered the judgment of thecourt.*1 1 Held: The appellate court affirmed thetrial court's termination of respondent's parental rightsbecause the trial court's unfitness and best interestfindings were not against the manifest weight of theevidence and the termination proceedings were notfundamentally unfair. 2 Respondent, Anezka L., is the mother of R.L.(born July 2020). In September 2024, the trial courtfound respondent was an unfit parent and terminationof respondent's parental rights would be in the minor'sbest interest. 3 Respondent appeals, arguing (1) the trial court'sunfitness and best interest findings were against themanifest weight of the evidence and (2) the terminationproceedings were fundamentally unfair. We disagreeand affirm. 4 I. BACKGROUND 5 A. Procedural History 6 In November 2021, the State filed a petition foradjudication of wardship, alleging R.L. was neglectedin that respondent (1) “failed to make a proper careplan for [R.L],” (2) “ha[d] substance abuse issues,” and(3) maintained a home with “unsanitary conditions.”See 705 ILCS 405/2-3(1)(a), (b) (West 2020). (Wenote that, prior to the filing of the petition, respondenthad participated in an intact case with the IllinoisDepartment of Children and Family Services (DCFS).) 7 Later that same month, the trial court conducteda shelter care hearing and placed temporary custodyand guardianship of R.L. with the guardianshipadministrator of DCFS. 8 In July 2022, respondent entered a writtenstipulation to the allegation that R.L.’s environmentwas injurious to her welfare due to the unsanitaryconditions of respondent's home, and the trial courtadjudicated R.L. neglected on that basis. 9 In August 2022, the trial court conducted adispositional hearing, at which it entered a writtenorder finding respondent “unfit, unable or unwilling”for reasons other than financial circumstances alone tocare for, protect, train, educate, supervise, or disciplineR.L. The court also (1) adjudicated R.L. a ward ofthe court, (2) placed guardianship and custody of R.L.with the guardianship administrator of DCFS, and (3)admonished respondent that she “must cooperate withDCFS, comply with the terms of the service plan, andcorrect conditions that require [R.L.] to be in care, orrisk termination of [her] parental rights.” 10 B. The Termination Hearing 11 In February 2024, the State filed a motion fortermination of parental rights, alleging that respondentwas an unfit parent because she (1) failed tomaintain a reasonable degree of interest, concern, orresponsibility as to R.L.’s welfare (750 ILCS 50/1(D)
In re R.L., Not Reported in N.E. Rptr. (2025)2025 IL App (4th) 241211-U © 2025 Thomson Reuters. No claim to original U.S. Government Works.2(b) (West 2024)); (2) failed to make reasonable effortsto correct the conditions that were the basis for theremoval of R.L. from her care within the nine-monthperiod of July 2022 to April 2023 (id. § 1(D)(m)(i));and (3) failed to make reasonable progress toward thereturn of R.L. to her care within the nine-month periodsof July 2022 to April 2023 and April 2023 to January2024 (id. § 1(D)(m)(ii)). 12 1. The Fitness Portion of the TerminationProceedings*2 13 In September 2024, the trial court conductedthe fitness portion of the termination proceedings. Atthe State's request, the court took judicial notice of allthe orders previously entered in the case, including theadjudicatory and dispositional orders. 14 a. Adriane Beck 15 Adriane Beck testified that from March 2022to August 2023, she was employed at the Center forYouth and Family Services (CYFS) and served asR.L.’s caseworker. Prior to Beck's involvement, R.L.had another caseworker as part of an intact case. 16 Beck testified that R.L. came into carefor “multiple reasons.” She explained that R.L.was “developmentally delayed” and the houseshe lived in with respondent was unsanitary.Additionally, respondent (1) “tested positive formeth[amphetamine],” (2) “was aggressive with theDCFS staff,” and (3) “had a history of *** assault withher mother with [R.L.] present.” Beck also testifiedthat respondent had a safety plan that she violated bybringing R.L. “somewhere *** she was not supposedto go” and respondent “only had one prenatal visit withR.L.” 17 When Beck took over as caseworkerin March 2022, the service plan that was inplace required the following services: “housing,employment, cooperation, parenting, substance abuse,visitation, anger management, parenting classes, and apsychological [evaluation],” as well as mental healthservices and random drug tests. 18 i. Psychological Evaluation and Mental HealthServices 19 Beck testified that respondent acted “defensive”about having to attend mental health services. Beckbelieved the services were necessary because shesaw numerous horizontal scars on respondent's arms.Beck also described two incidents in May 2022during which respondent exhibited unusual behavior.During one visit, respondent gave R.L. a haircut, butwhen the haircut did not turn out well, respondent“became extremely upset and was screaming andcursing and punching herself in the head.” Aroundthe same time, during a family and team meeting todiscuss appropriate dress with respondent after she hadaccidentally exposed her breast to a male case aide, she“became very angry and started screaming, cursing at[Beck and her supervisor], and she was asked to leaveat that point.” 20 Beck stated that respondent completed apsychological evaluation, which resulted in therecommendation that she (1) see a psychiatrist formedication and medication management and (2) seea counselor weekly. Beck testified that respondentgenerally attended counseling, although she missed 5out of 10 sessions due to her phone being off andoversleeping. By April 2023, the counselor reportedto Beck that, despite missing half of her sessions,respondent was communicating well, in that she wasnot getting angry or exploding, but she was notengaging. Beck explained that “she still wasn't divinginto anything to do with her mental health that wassubstantial.” 21 ii. Substance Abuse Treatment and Drug Tests 22 Beck testified that by May 2022, respondentwas engaged in outpatient treatment services atGateway Foundation (Gateway) and she completedthose services around September 2022. However,between March 2022 and August 2022, respondentdid not attend any of the drug tests requested by theagency. Overall, between March 2022 and August2023, although the agency requested four drug testsper month, respondent attended only four or five intotal. Respondent told Beck that her work schedule was
In re R.L., Not Reported in N.E. Rptr. (2025)2025 IL App (4th) 241211-U © 2025 Thomson Reuters. No claim to original U.S. Government Works.3getting in the way of her attending the drug tests, butwhen Beck asked for respondent to provide her workschedule so Beck could accommodate her, respondentnever did so.*3 23 Beck testified that in June 2022, respondenttested positive for alcohol while she was in theGateway program and tested positive for marijuana on“more than one occasion.” 24 Beck also testified that respondent told her she wasusing marijuana daily to treat her anxiety. Beck stated,although respondent's marijuana use was not illegal,it prevented Beck from getting an accurate picture ofrespondent's mental health. Additionally, respondentwas using marijuana while pregnant. 25 On cross-examination by the guardian ad litem(GAL), Beck testified that in June 2023, respondenttold her she had been drinking alcohol and was nolonger pregnant. 26 iii. Parenting Classes 27 Beck testified that respondent completedparenting classes around May 2022. However, becauseshe was “struggling” with staying in contact and theservice provider believed she was overwhelmed withservices, the provider recommended that she alsocomplete parenting coaching in the future, when R.L.was closer to being returned home. 28 iv. Anger Management Classes 29 Respondent completed anger management classesin January 2023. However, by August 2023, Beck stillhad concerns about respondent's ability to manage heranger. Beck explained that, around April 2023, whenissues started arising over the home safety checks,“that's when it started to get bad again and we startedhaving a lot of trouble being able to communicatebecause of aggression.” 30 v. Visits, Housing, Employment, and Cooperation 31 Between March 2022 and August 2022,respondent was given one visit per week and had beenapproved for home visits. However, after “a month ortwo,” respondent reported a roach infestation in herhome, so visits occurred at the office until a safetycheck could occur. Respondent generally attendedthe visits at the office, although she did have issuesarriving on time. Also, case aides reported issueswith respondent not being prepared with food anddiapers and “hitting her vape in a few different visits.”Beck conducted at least four home safety checks butwas never able to deem respondent's home safe andappropriate, so visits with R.L. at home never resumed. 32 In April 2023, at one of those safety checks,when Beck arrived at respondent's home, respondentanswered the door in her robe and said she forgotthat they were coming over. She said her “lights hadbeen shut off for failure to pay the bill.” Beck couldsee that the house was “still very cluttered” and therewas a “very, very strong smell of marijuana.” Therewas also a man in the bed that respondent did notintroduce to Beck. Beck later learned that the manin the bed was “Malcolm” and that respondent waspregnant. Respondent had not reported Malcolm as aparamour. 33 Regarding communication, Beck testified thatbetween March 2022 and August 2023, she spoke withrespondent every other week and met with respondentevery other month, if not more. Beck stated that shemet with respondent more than other parents becauseshe was “trying to get her to engage and help herunderstand why she needed to engage so that she couldbe successful and [R.L.] could be returned home toher.” 34 Beck also testified that, in June 2022 and July2022, respondent was “mak[ing] some progress incooperating with the agency” and, at the time ofBeck's August 2022 disposition hearing report, shebelieved respondent had made some progress towardreunification with R.L. In her opinion, from August2022 to January 2023, respondent was “making greatprogress in the cooperation realm,” noting that “[s]hewas awesome to work with.” Beck had increasedrespondent's weekly visits to three hours because shewas “compliant *** and pleasant” and “was doing wellwith her daughter.”
In re R.L., Not Reported in N.E. Rptr. (2025)2025 IL App (4th) 241211-U © 2025 Thomson Reuters. No claim to original U.S. Government Works.4*4 35 Nonetheless, in April 2023, Beck started“having issues with cooperation *** and *** heranger again,” explaining that things started to godownhill after the April 2023 home safety checkwhen Malcolm was present. Immediately after thatincident, respondent would become angry when Beckand respondent talked on the phone, she begancursing again, and the communication became lessfrequent. Beck stated this behavior persisted for therest of her time as caseworker. She also explainedthat respondent's cluttered house prevented her fromallowing home visits because a child of R.L.’s age, whohad just begun walking, could grab things and put themin her mouth. Beck did not believe respondent “ma[d]eprogress on her treatment goals.” 36 On cross-examination by the GAL, Beck testifiedthat although respondent's visitation time increased tothree hours per week, Beck never advanced the visits tounsupervised status. Beck also testified that while shewas the caseworker, she never reached a point that shewould have recommended to return custody of R.L. torespondent. 37 b. Officer Trevor Davis 38 The State called Officer Trevor Davis of theSpringfield Police Department, who testified about anincident in November 2023 when he was dispatchedto respondent's home. Respondent was on the frontporch, and Malcolm was inside. Respondent identifiedMalcolm as her ex-boyfriend, stating that they hadbeen dating for two years and were now broken up, butshe allowed him to still stay at her home. Davis statedthat respondent had called the police and reportedthat Malcolm was threatening her with an axe, soshe threw a broom at him. When Davis spoke withrespondent, she was “very loud, she was yelling at uslike she was mad at us.” He said it was hard to collectinformation from her. He did not believe she was underthe influence of alcohol but thought “maybe she washaving some kind of a mental health episode or maybeshe was on something.” 39 When respondent overheard Malcolm telling thepolice that respondent had kicked him in the face, shethen told Davis that Malcolm had hit her seven or eighttimes. Davis tried to ask her about the axe, but “sherefused to speak.” 40 Davis testified that he and another officerattempted to place them both under arrest, butrespondent would not get in the squad car and kickedanother officer in the stomach. Davis testified thathe arrested respondent for domestic battery, resistingarrest, and aggravated battery, but he was unaware ifthe State formally charged her in court. 41 c. Hayley McAfee 42 Hayley McAfee testified that she was employedat CYFS and was respondent's caseworker fromSeptember 2023 to present. When McAfee took overas caseworker, respondent's service plan required“substance abuse, anger management, psychological,[and] mental health [services], visitation, cooperation,toxicology screens” and a “parenting capacityassessment to be determined if she were to everengage,” which “DCFS at the time was not approving*** due to her lack of engagement.” Respondentwas also required to maintain stable housing andemployment. 43 McAfee testified that, as part of respondent'sservice plan, respondent was required to provideverification of any progress in services to McAfee.However, respondent never provided McAfee anyreports of progress in counseling, substance abuse, orpsychiatric treatment. 44 i. Mental Health Services 45 McAfee testified that when she took overthe case in September 2023, she received reportsthat respondent's engagement in counseling wasdecreasing. Respondent would attend only virtualsessions and would often be late or cancel the sessions.When she did attend, she questioned why she neededto be there and would not “establish any goals withher counselor or dig into *** any of her trauma or pasthistory.”*5 46 McAfee also testified that in November2023, she conducted a family and team meeting over
In re R.L., Not Reported in N.E. Rptr. (2025)2025 IL App (4th) 241211-U © 2025 Thomson Reuters. No claim to original U.S. Government Works.5the phone, during which she spoke to respondentabout her mental health services. McAfee testifiedthat respondent became upset about being asked todo mental health services because she did not believeshe needed counseling or medication. Respondent toldMcAfee that a doctor had prescribed her medicationbut she would not be filling the prescription becauseshe did not believe the diagnosis was accurate. Themeeting ended early because respondent angrily hungup the phone. 47 Respondent's counselor left in November 2023,and McAfee offered respondent another counselorwith the same agency; however, respondent declinedand said she would find her own. In February 2024,respondent reported that she was on a waiting list fora new counselor. After a few months of no progress,around May 2024, McAfee referred respondent backto CYFS for a counselor, and respondent was placedwith a new counselor in June 2024. 48 Between September 2023 and February 2024,respondent did not provide any verification that shewas engaging in psychiatric services or taking herprescribed medication. 49 ii. Substance Abuse Treatment and Drug Tests 50 McAfee testified that in November 2023,respondent had still not provided a work schedule,which was a “topic of contention” because McAfeeneeded to know what days respondent could attenddrug tests or whether the days she missed qualified asexcused absences. 51 Between September 2023 and January 2024,McAfee requested 20 weekly random drug tests, butrespondent attended only 6. Of those six, “[t]wo orthree [were] adulterated” and two were positive foralcohol. McAfee testified that respondent's alcohol usewas “definitely not safe for her unborn child, andcoupled with her mental health diagnosis and lackof treatment, lack of engagement in counseling, thealcohol seemed like a poor coping mechanism.” 52 However, McAfee also testified that respondentreengaged in Gateway's outpatient treatment programin January 2024 and graduated in August 2024. 53 iii. Anger Management 54 In November 2023, although respondent hadpreviously completed an anger management program,McAfee referred her to be “assessed for domesticviolence and anger management” services due to theNovember 2023 arrest. As a result of the assessment,respondent was asked to complete another 26 angermanagement sessions. In July or August 2024, whenMcAfee found out respondent was dating Malcolmagain, she reported the relationship to the serviceprovider. The provider advised that respondent hadbeen denying the relationship. Accordingly, due torespondent's “not being honest and forthcoming,” theservice provider increased her session requirementto 40. As of August 2024, respondent had notcompleted anger management sessions but was“making progress.” 55 iv. Visits, Housing, and Cooperation 56 McAfee conducted a home safety check in June2024. Although she “had some concerns,” she said“it would “likely be deemed safe.” McAfee becameconcerned a male was living in the house because sheobserved a lot of “workout powders” on top of therefrigerator, but respondent told McAfee that she wastaking the powders to gain weight. 57 The following day, McAfee asked respondentabout her relationship status and “we ended updiscovering that she was pregnant this summer[(2024)].” McAfee asked for several weeks whothe father was, and respondent finally disclosed thatthe father was Malcolm and that they would bein a relationship going forward. This informationconcerned McAfee because the pair had been arrestedfor domestic violence in November 2023. Moreover,respondent had claimed they were not in a relationship,but “it appears that maybe they have been in onethis entire time and she wasn't disclosing it.” McAfeeadded that Malcolm would be required to completeservices due to the incident with the police. McAfeealso testified that respondent did not tell her about thearrest; instead, McAfee learned about it in the news.
In re R.L., Not Reported in N.E. Rptr. (2025)2025 IL App (4th) 241211-U © 2025 Thomson Reuters. No claim to original U.S. Government Works.6*6 58 McAfee also testified that Malcolm hadnot yet engaged in any domestic violence or angermanagement courses, although McAfee had “laid outthe things he can get started on himself before hisunborn child is born.” 59 McAfee testified about visitation betweenSeptember 2023 and the present. She stated thatweekly visits occurred between September 2023 andearly March 2024 and, since March 2024, the visitshad become biweekly. Prior to the visits becomingbiweekly, respondent had attended only 6 out of 20visits and arrived late for some of the visits that she didattend. 60 v. Parenting Capacity Exam 61 On cross-examination by respondent, McAfeetestified that she had requested a parenting capacityexam, which DCFS denied due to respondent's lackof progress. However, McAfee had “since requestedthat [again] since she's made more progress,” andher request was approved and scheduled for March2025. She requested the parenting capacity evaluationbecause R.L. “has special needs.” The exam would “gointo whether or not [respondent] can meet *** [R.L.’s]safety needs [or] her emotional needs, keep up withwhat she's going to need through school, her doctors’appointments, and things like that.” 62 Respondent's counsel asked McAfee whatprogress respondent was now making that led toDCFS approving the exam. McAfee answered thatrespondent was now more cooperative, had completedher drug program, and was attending drug tests andstaying sober “for the last couple months it appears.”McAfee also testified that respondent was engaged incounseling but emphasized that respondent caused adelay by choosing to seek her own counselor and thennot doing so for three months before being waitlisted.McAfee further stated that respondent's lack of honestyabout Malcolm “waste[d] eight months getting himengaged in the case.” Also, although she was attendingher additional anger management sessions, she wouldnot graduate for another four and a half months. 63 McAfee also expressed concern about R.L.’ssafety or what she might witness in respondent's careif an incident like the one in November 2023 withMalcolm were to occur. 64 d. Respondent 65 Respondent testified that to address her substanceabuse issues she obtained a new job, was “trying tocomplete [her] services,” and was “doing [her] copingskills.” She graduated from the Gateway program andenjoyed it. 66 She also testified that she tried her best duringher mental health sessions but did not feel thatshe connected with her first counselor. When thatcounselor left, respondent opted to find her owncounselor because she did not believe she wouldconnect with any counselor at that agency. Sheapproached Memorial Behavioral Healthcare, but they“stopped the whole session” when they found outshe was involved with DCFS. Respondent then wentto Survivor Recovery, where she was waitlisted.Eventually, she went back to CYFS, where she begancounseling with a new counselor. Although she hadbeen seeing her for only a couple months, respondentfelt that things were going better. 67 Respondent also testified that she had maintainedemployment throughout the case, first at Dairy Queen,then at McAllister's Deli, and currently at Delta Vapes.She stated that she sent her work schedule to her firstcaseworker, Beck, but was not sure if she sent McAfeeany of her schedules, although she had “recently” beensending McAfee her schedule at Delta Vapes. Shealso testified that she had lived in the same apartmentthroughout the case, which she described as a “prettysmall” studio apartment. She had been organizing itlately and made R.L. her own room.*7 68 Respondent also testified about the November2023 incident with Malcolm. She said they had bothbeen drinking that night. When asked what steps shewas taking to make sure that no similar incident wouldhappen again, respondent said that she was takingdomestic violence classes “right now” and havingconversations with Malcolm about “how we reallyneed to get it together.” Counsel asked if respondent“work[ed] on those type of issues in counseling,” andrespondent said, “No, because honestly ever since
In re R.L., Not Reported in N.E. Rptr. (2025)2025 IL App (4th) 241211-U © 2025 Thomson Reuters. No claim to original U.S. Government Works.7that incident happened, we haven't really had anyproblems.” 69 Respondent testified that Malcolm was willingto do any services needed for respondent to get R.L.back. She was willing to continue with her drug screensand parenting classes. She said she was a completelydifferent person than she was three years ago, and shejust wanted “another chance to bring [her] daughterhome.” 70 On cross-examination by the State, respondenttestified that she did not tell the agency about herrelationship with Malcolm earlier because she felt like“they're just going to be mean to me or something orstart unnecessary drama.” She said, “[T]he only reasonthey're nice to me now is because I have an advocate.” 71 Respondent testified that she did not believeMalcolm posed a risk to her sobriety because “he isalso sober now.” She also did not feel that he posed arisk to her reunification with R.L. because “[a]s longas he does his services, I feel like everything should befine.” 72 Respondent also testified that she last drankin “January of this year or February” and Malcolmlast drank four months ago. When asked whether shesometimes used cannabis or marijuana, respondentanswered, “Yes,” and testified that she last usedmarijuana “[p]robably a couple days ago.” Whenasked when Malcolm last used marijuana, respondentanswered, “Probably a couple days ago with me.” 73 On cross-examination by the GAL, respondenttestified that she graduated from the Gateway programin September 2023, then the incident with Malcolmoccurred in November 2023. She was not currentlyattending any substance abuse treatment. 74 e. Erica Volentine 75 Erica Volentine testified that she becamerespondent's advocate at Primed for Life in January2024. She testified that, since she was involved withrespondent, respondent had made “excellent progress”in her services. Volentine had visited respondent inher home “four or five times” and believed it wasappropriate for R.L. Volentine believed respondent hadcontrol of her anger issues, was aware of R.L.’s specialneeds, and was able to parent her appropriately. 76 On cross-examination by the State, Volentinetestified that respondent mentioned Malcolm at theirfirst meeting in January 2024, but they did notdiscuss him “in depth” until later, in July 2024,when respondent told Volentine that she was pregnant.When discussing the pregnancy and respondent'srelationship with Malcolm, they discussed servicesDCFS might request him to complete. He appearedwilling to cooperate. Volentine did not have anyconcerns about Malcolm posing a risk to respondent'ssobriety. Volentine testified that she was “not sure”what services he had accomplished since then.Volentine had given him information about a parentingclass, substance abuse treatment, and mental healthtreatment, but she did not know if he had voluntarilyundertaken any of those services. 77 f. The Trial Court's Ruling 78 The trial court first noted that much of theevidence presented at the fitness hearing related not torespondent's fitness but instead to R.L.’s best interest;the court stated that it was not considering any of theevidence that was unrelated to the fitness allegations.*8 79 The trial court began its ruling by noting thatrespondent had engaged in services, completing many,and that she had engaged in visits, although “therewere still some issues,” such as visits having to bemoved out of the home and respondent arriving late.The court then observed, “But this case is more thanabout just checking off boxes. Was there benefit fromthose services?” The court pointed out that althoughrespondent had completed anger management classes,afterward, in November 2023, she had a physicalaltercation with Malcolm, during which, despite“having gone through anger management [and] beingin counseling, her reaction *** was to kick the officer.”The court noted that although she “checked off someboxes,” she had not made progress by then. 80 The trial court then addressed the April 2023home safety check, noting that “the case was actuallyadjudicated for basically the minor's environment
In re R.L., Not Reported in N.E. Rptr. (2025)2025 IL App (4th) 241211-U © 2025 Thomson Reuters. No claim to original U.S. Government Works.8[being] injurious to her welfare as evidenced by theunsanitary conditions in the home,” yet “nine monthsafter adjudication,” at the home safety check, “[b]illshadn't been paid, so there was no electricity. She hada man on her bed she had never told DCFS about. Shesaid at that time she was pregnant. The home was verycluttered. There was a strong smell of marijuana.” Thecourt noted that, even by August 2023, according to thecaseworker, the home was “still not safe or appropriatefor visits,” let alone for R.L. to live in. 81 The trial court also noted that, by April 2023—the end of the first nine-month period—respondent wasnot engaging in her counseling sessions and had missedhalf of them. Also, although the caseworker stated inJanuary 2023 that things were improving, by April2023, respondent began showing signs of aggressionagain. 82 The trial court observed that by November2023, respondent was “still not acknowledging that sheneeded mental health treatment.” Indeed, respondent“didn't believe she had a mental health diagnosis,she didn't want medication, she didn't believe thatshe needed treatment.” A doctor prescribed hermedication, but respondent did not fill the prescription.The court found, “So clearly by November [2023,respondent] was still not at that point where she wasready to *** make progress.” The court questionedwhether that was due to respondent still using alcoholand cannabis but found that “despite having gonethrough certain services, being engaged in services, byNovember [2023], she still wasn't there, she still wasn'tacknowledging what went on and what she needed todo for her sake as well as for her child.” 83 The trial court had “great concern” that after theNovember 2023 incident with Malcolm, respondentwas assessed for anger management and domesticviolence, stating, “[G]osh darn it, she lied to them.She never told them she was in a relationship withMalcolm *** despite that being an issue.” The courtstated, “That's a huge concern for me. She didn't tellGateway, she didn't tell the caseworker. She finds outin March [2024] that she's pregnant, so obviously she'sbeen engaging with Malcolm prior to that.” The courtcontinued, “[S]he wasn't open, she wasn't honest. Andthat's a huge red flag for me. Considering how seriousthat incident in November was, *** she didn't tellGateway because she didn't want the drama, she didn'ttell the caseworker because she didn't want the drama.”The court noted that respondent's lack of honesty wasa “huge issue” because “[e]ven the Primed for Lifeadvocate said it would probably make a difference ifthey'd have known in March that she was pregnant byMalcolm.” 84 The trial court noted that in January 2024—theend of the second nine-month period—“there's stillissues with her being on time for visits, missing visits,a significant number of visits.”*9 85 The trial court observed that the law givesa parent nine months to make reasonable efforts andreasonable progress and, in this case, respondent'sprogress came after two nine-month periods hadalready elapsed. The court then found as follows:“I find by clear and convincing evidence that[respondent] failed to demonstrate a reasonabledegree of certainly responsibility as to the minor'swelfare, and largely that is because of not fullyengaging, not being open, not engaging with herservices to show that it was making a difference. Soagain, clearly she did not make reasonable effortsto correct conditions. The home was still unable tohave visits in. She still did not make reasonableprogress towards having the child returned to herduring both of the nine-month time periods.At no point in time up through January of ’24 wasI able to say I was close to being able to return thischild to [respondent's] care, and that is the objectivestandard that I am to use. So for those reasons, I dofind that [respondent] is an unfit parent based uponthe allegations in the petition.” 86 2. The Best Interest Portion of the TerminationProceedings 87 That same day, after the conclusion of the fitnessportion of the termination proceedings, the trial courtconducted the best interest portion of the terminationproceedings. At the State's request, the court tookjudicial notice of the testimony presented during thefitness portion of the termination proceedings.
In re R.L., Not Reported in N.E. Rptr. (2025)2025 IL App (4th) 241211-U © 2025 Thomson Reuters. No claim to original U.S. Government Works.9 88 a. McAfee 89 The State again called McAfee, who testified thatshe visited R.L. in her foster home “[a]t least monthly.”R.L. had been living in her current foster home sincecoming into care in November 2021, when she was 16months old. She had a foster sister in the home whobegan living there at two days old and who was nowtwo years old. McAfee said R.L.’s relationship with herfoster sister was “very close.” 90 McAfee testified that when R.L. came into care,she was unable to walk or communicate. McAfeestated, “She was food-hoarding, head-banging, andjust, she seemed very delayed compared to an average16-month-old.” Now, at four years old, R.L. had “madea lot of improvements ***, but she still does havesome developmental delays compared to her peers.”R.L.’s foster parents took her to monthly occupationaltherapy and speech therapy sessions and pediatricianappointments. 91 McAfee testified that R.L. was doing “[g]reat”in her foster home. She stated, “[R.L.] is consistentlyimproving, gaining skills, filling the gap on herdevelopmental delay, and just like learning the skillsand things that we weren't ever really sure she wouldbe capable of, so she just keeps excelling [beyond]everyone's expectations.” McAfee stated that R.L.’sfoster parents were taking care of all of her emotional,mental, and educational needs. She described the bondbetween R.L. and her foster parents as “very strongand secure,” adding that she “looks to them in *** hermoments of chaos for some peace.” R.L. called herfoster parents “[m]om and dad,” and her foster parentswished to adopt her. 92 McAfee also testified that respondent hadnever participated in any of R.L.’s therapy ormedical appointments. When R.L. came intocare, she had missed six well-child appointments,which was concerning to McAfee because R.L.’sdevelopmental delays were not being brought tothe attention of a doctor who could provideinterventions. McAfee expressed concern aboutrespondent's ability to take R.L. to her therapy andmedical appointments, specifically noting respondent'sdifficulty with “[p]lanning and time management.”McAfee elaborated that respondent “continues tobe late to visitation [and] sleep through herappointments,” and she pointed out that respondentwas late to court that day.*10 93 McAfee believed it was in R.L.’s bestinterest that respondent's parental rights be terminatedso R.L. could have permanency. McAfee explainedthat R.L. was getting old enough that “she's seeingthese other kids with *** normal lives, and shedeserves to not have these question marks foranother unknown amount of time.” McAfee added,“[Respondent's] been given plenty of opportunity toresolve these *** problems, and [R.L.] just needs to beable to move on in her life with whichever directionthis goes.” 94 On cross-examination by respondent's counsel,McAfee testified that R.L. also had a bond withrespondent, which she described as a “big-sister bond.”She explained, “[I]t's always fun and good, it's for acouple hours at a time, they're always doing somethingfun and exciting.” She added, “[R.L.] knows that's herother mom, but at the end of the day, it's her fosterparents taking her to her doctors’ appointments andshowing up to school for her and helping her whenshe's sick and things like that.” McAfee testified thatR.L. called respondent “mom” and says that she lovesher. McAfee stated that the foster parents were opento maintaining a relationship between respondent andR.L. 95 b. Jessica W. 96 Jessica W. testified that she had been R.L.’sfoster parent for the last two and a half years. Jessica'shusband was “the best of friends” with R.L., and theyshared a strong bond. She stated, “[W]hen [R.L.] seeshim, she gets excited,” and “if we are all going onan outing, she wants to make sure that my husbandis going along with us just so we can all experienceit together as a family.” When R.L. came into hercare, R.L. “wasn't babbling or anything” and “was notwalking or moving a whole ton.” R.L. was initially notengaging socially at all with Jessica or her husband.They worked with R.L. to get her to “realize that shehad legs” by doing things like putting her in a bouncer.Within about a month, R.L. was crawling.
In re R.L., Not Reported in N.E. Rptr. (2025)2025 IL App (4th) 241211-U © 2025 Thomson Reuters. No claim to original U.S. Government Works.10 97 Jessica testified that initially, R.L. had somebehavioral issues, such as head banging, scratching,and pocketing food in her mouth. She also had someinitial difficulty with navigating the classroom andbeing around peers in the pre-K program she wasenrolled in. However, she no longer demonstratedthose behaviors and overcame her issues in pre-K.Jessica said that R.L. was now running around withher friends at the park and described her speech as“incredible,” noting, “She's able to tell us how she'sfeeling now,” and “she's just an overall healthy littlegirl.” 98 Jessica testified about R.L.’s relationship with herfoster sister, describing them as “like typical sisters”who “love to play.” Jessica also testified that shehas extended family in the area with whom R.L. haddeveloped relationships, including Jessica's nieces andnephews. Jessica said R.L. called Jessica's parents“Gigi and Papa.” R.L. liked to go to their home, whereshe swings, rides in a golf cart, reads books, andwatches movies with her foster grandparents. 99 On cross-examination by respondent's attorney,Jessica testified that R.L. appeared to enjoy the timeshe spent with respondent. She said that R.L. onlyrecently began talking about respondent, calling her“new mommy.” 100 c. Volentine 101 Volentine testified that she had observed onethree-hour visit and “a partial other visit.” She saidrespondent was prepared with a craft project, brought ameal, checked R.L.’s diaper, and was “communicativeand age-appropriate.” Volentine testified that there wasa bond between respondent and R.L. that she describedas “affectionate” and “very close.” She said R.L. didnot become upset at the end of the visits becauserespondent “prepares her” for the visit to end. Shebelieved that R.L. would be harmed by having nocontact with respondent. 102 d. Respondent*11 103 Respondent testified that R.L. “was alwaystalking since she was about six or five months old” andshe stopped talking only after she was taken into DCFScustody. She also said that she had videos of R.L. tryingto walk before she was taken into custody but stated,“I just feel like she didn't want to walk in front of me.” 104 Respondent testified that she had a “great bond”with R.L., adding, “We've always been the best offriends” and that R.L. called her “mom.” She believedthat R.L. would be “affected mentally if [respondentwas] not in her life,” stating that R.L.’s being takenaway from her “did developmentally delay her andaffect her already.” 105 Respondent believed she could provide for all ofR.L.’s needs and that she would “drop whatever [she]was doing” if R.L. needed her. She believed she couldtake care of R.L.’s educational and medical needs andalso provide emotional support and protection. 106 On cross-examination, the GAL askedrespondent why she missed six well-child visits beforeR.L. was taken from her. She answered, “I'm going tobe honest. That was just me not wanting to go to thedoctor. Now I know that I should have been taking herto the doctor, absolutely. I've learned from that.” 107 e. The Trial Court's Ruling 108 The trial court found that it was in R.L.’s bestinterest to terminate respondent's parental rights. Thecourt noted that R.L. had been in her current fosterhome “for most of her life” and had bonded with herfoster parents and sister. The court acknowledged thatR.L. enjoyed her visits with respondent but noted thatR.L. also needed structure, which the court did notbelieve respondent could provide. The court stated thatit did not know when respondent might be able toprovide that structure and that it did not want to leaveR.L. in limbo. 109 The trial court stated the following:“So when I look at all of the [statutory best interest]factors, where she feels secure, where she goes forhelp on a day-to-day basis, who gets her up inthe morning, who feeds her, who clothes her, who
In re R.L., Not Reported in N.E. Rptr. (2025)2025 IL App (4th) 241211-U © 2025 Thomson Reuters. No claim to original U.S. Government Works.11gets her to school, who gets her to her doctors’appointments, that's been the foster parents for mostof her life now.******So I do find considering all the factors we've gonethrough that the State has shown by a preponderanceof the evidence that it is in the best interest ofthe minor that [respondent's] parental rights beterminated. I agree with [the GAL]; she needspermanence, she needs to no longer be in limbo.” 110 This appeal followed. 111 II. ANALYSIS 112 Respondent appeals, arguing (1) the trial court'sunfitness and best interest findings were against themanifest weight of the evidence and (2) the terminationproceedings were fundamentally unfair. We disagreeand affirm. 113 A. Accelerated Appeal Filing Deadline 114 Initially, we note that this is an accelerated appealunder Illinois Supreme Court Rule 311(a) (eff. July 1,2018). Under that rule, this court is required to issue itsdecision in an accelerated case within 150 days afterthe filing of the notice of appeal unless there has been“good cause shown.” Ill. S. Ct. R. 311(a)(5) (eff. July1, 2018). 115 Here, respondent's notice of appeal was filedon September 13, 2024, and this court's dispositionwas due to be filed by February 10, 2025. That filingdeadline has passed. However, we note that respondentfiled three motions for an extension of time to file herbrief, on November 8, 2024, January 13, 2025, andApril 14, 2025. This court granted each of respondent'srequests for extensions of the deadline to file her brief.*12 116 We also note that, shortly after thecompletion of the briefing in this case in late May2025, this court became aware that appellant's attorney,William T. Panichi, had potentially violated IllinoisSupreme Court rules and Illinois Rules of ProfessionalConduct in other pending appeals. Subsequently, onJuly 21, 2025, this court issued its decision in, Inre Baby Boy, 2025 IL App (4th) 241427, ¶¶ 110,112, sanctioning attorney Panichi for violating IllinoisSupreme Court Rule 341(h)(7) (eff. October 1, 2020),by “citing cases that do not exist for principles of lawthat do not exist,” which constituted a violation ofIllinois Rules of Professional Conduct of 2010 3.1, 3.3(eff. Jan. 1, 2010) and 8.4 (c) (eff. July 1, 2024) by“making false statements and misrepresentations of theapplicable law to this court.” This court also concludedthat attorney Panichi violated Illinois Supreme CourtRule 375(b) (eff. Feb. 1, 1994) by “citing fictitiouscases for propositions that were not supported byexisting law.” Baby Boy, 2025 IL App (4th) 241427, 118. 117 Additionally, on August 7, 2025, this court filedits decision in In re S.M., 2025 IL App (4th) 250277-U, 32, again sanctioning Panichi for “willfully citingmultiple cases that do not exist or do not stand forthe propositions of law for which they were cited.”See In re A.S., 2025 IL App (4th) 250298-U, ¶¶ 18-20(issued August 4, 2025, and imposing sanctions uponPanichi for citing cases that do not exist). In S.M.,S.S., and Baby Boy, sanctions were imposed followingrule to show cause proceedings, and in each case,Panichi has been referred to the Attorney Registrationand Disciplinary Commission (ARDC). Since BabyBoy was issued, Panichi has stated that he is “workingon closing out [his] practice appropriately andsurrendering [his] license.” Springfield Attorney Finedfor Using AI, Citing ‘Nonexistent’ Cases (Aug. 1,2025) https://www.wcia.com/news/sangamon-county/springfield-attorney-fined-for-using-ai-citing-nonexistent-cases. 118 Addressing Panichi's misconduct, which alsooccurred in the present case (as we discuss infra ¶¶ 139,152), required a uniform response by this court andcaused further delay in the issuance of our decision.We note that, although Panichi has cited nonexistentcases and cases that do not stand for the propositionsof law asserted, because Panichi has already beenreferred to the ARDC and is surrendering his license,we have elected to not pursue sanctions in the presentcase, which would require further rule to show causeproceedings and cause further delay.
In re R.L., Not Reported in N.E. Rptr. (2025)2025 IL App (4th) 241211-U © 2025 Thomson Reuters. No claim to original U.S. Government Works.12 119 Given respondent's motions for extensions oftime and misconduct, we conclude that there is goodcause for issuing our disposition after the 150-daydeadline. 120 B. Appellant's Brief 121 We must also address the sufficiency ofappellant's brief. The State argues that respondent hasforfeited each of her arguments because her brief failsto comply with Illinois Supreme Court Rule 341(h)(7) (eff. Oct. 1, 2020), which requires an appellant'sbrief to include “[a]rgument, which shall contain thecontentions of the appellant and the reasons therefor,with citations of the authorities and the pages of therecord on appeal relied on.” We agree with the Statethat respondent's brief is deficient in that it fails toreference the pages of the record relied upon andpresents claims that are not supported by developedargument and citation to relevant authority. 122 Although this court would be well within itsauthority to not only consider respondent's claimsforfeited, we also retain the discretion to strikerespondent's brief and dismiss her appeal. Freedmanv. Muller, 2015 IL App (1st) 141410, 22. However,because we are able to discern respondent's argumentson appeal and the record is sufficient for us todetermine the issues on appeal, in the interest ofobtaining permanency for R.L., we elect instead toaddress the appeal on its merits. 123 C. The Trial Court's Fitness Determination*13 124 It is well settled that “[b]ecause eachof the statutory grounds of unfitness is independent,the trial court's finding may be affirmed where theevidence supports a finding of unfitness as to any oneof the alleged grounds.” In re Adoption of P.J.H., 2019IL App (5th) 190089, 11. Based on our review ofthe record, we conclude that the court's finding thatrespondent failed to make reasonable progress withineither of the nine-month periods alleged in the petition(July 2022 to April 2023 and April 2023 to January2024) was supported by the evidence. Accordingly, wediscuss only that finding. 125 1. The Applicable Law and the Standard ofReview 126 The State must prove unfitness as defined insection 1(D) of the Adoption Act (750 ILCS 50/1(D)(West 2024)) by clear and convincing evidence. In reN.G., 2018 IL 121939, 28. Section 1(D)(m)(ii) of theAdoption Act defines an unfit person as a parent whofails to make “reasonable progress toward the return ofthe child” during any nine-month period following anadjudication of neglect or abuse. 750 ILCS 50/1(D)(m)(ii) (West 2024). Reasonable progress is an objectiveview of the steps the parent has taken toward the goalof reunification and examines the demonstrability andquality of those steps. In re Ta. T., 2021 IL App (4th)200658, 51. Additionally, the Illinois Supreme Courthas held that “the benchmark for measuring a parent's‘progress toward the return of the child’ under section1(D)(m) of the Adoption Act encompasses the parent'scompliance with the service plans.” In re C.N., 196 Ill.2d 181, 216 (2001). Reasonable progress exists whenthe trial court can conclude that, in the near future, itwill be able to order the children returned to parentalcustody. Ta. T., 2021 IL App (4th) 200658, 51. 127 A determination of parental unfitness involvesfactual findings and credibility determinations that thetrial court is in the best position to make. In re M.I.,2016 IL 120232, 21. Accordingly, a trial court'sfinding of parental unfitness will not be reversed unlessit is against the manifest weight of the evidence.N.G., 2018 IL 121939, 29. A decision is against themanifest weight of the evidence when the oppositeconclusion is clearly apparent. Id. 128 2. This Case 129 The evidence in this case supports the trial court'sfinding that respondent was unfit because she failed tomake progress toward the return of R.L. during eitherof the nine-month periods alleged in the petition. 130 Beck was the caseworker from March 2022to August 2023, which covered the entirety ofthe first nine-month period (July 2022 to April2023) and half of the second nine-month period
In re R.L., Not Reported in N.E. Rptr. (2025)2025 IL App (4th) 241211-U © 2025 Thomson Reuters. No claim to original U.S. Government Works.13(April 2023 to January 2024), while McAfeewas the caseworker for the second half of thesecond nine-month period and thereafter. Respondent'sservice plan required participation in mental healthservices, substance abuse treatment and random drugtesting, parenting classes, anger management classes,visitation, cooperation, and maintenance of housingand employment. 131 Respondent completed a psychologicalevaluation, but she never completed mental healthcounseling or complied with psychiatric treatment.She completed outpatient substance abuse services atGateway but continued using alcohol and marijuana.She also failed to attend the vast majority of herrandom drug tests. Although she later reengaged atGateway in January 2024 and graduated in August2024, that occurred well after the end of the secondnine-month period. At that point, R.L. had been infoster care for nearly three years.*14 132 Respondent completed parenting classes,but the service provider reported that she struggledwith maintaining contact with the parenting coachand recommended further parenting coaching whenR.L. was closer to being returned home, which neveroccurred due to respondent's lack of progress inservices. Although McAfee twice referred respondentfor a parenting capacity examination, the first referralwas denied due to respondent's lack of progress inservices and the second was approved to begin inMarch 2025, again, well after the expiration of thesecond nine-month period. 133 Respondent also completed anger managementclasses but was rereferred for more classes after theNovember 2023 arrest, during which she admitteddrinking alcohol and kicked a police officer in thestomach. While engaged with her second roundof anger management classes, McAfee learned thatrespondent was untruthful about the status of herrelationship with Malcolm and, as a result, she wasrequired to complete additional classes. As of August2024, well after the end of the second nine-monthperiod, she had still not completed anger managementclasses. 134 During the first nine-month period, respondentlargely attended her weekly visits, although shereportedly had issues with being prepared. McAfeetestified that, from September 2023 to March 2024,which encompassed the second half of the second nine-month period, respondent attended only 6 out of 20visits and arrived late for some of those visits she didattend. Although McAfee said that in June 2024, shewould likely have deemed the home safe, that was fivemonths after the expiration of the second nine-monthperiod in January 2024. Respondent's visits with R.L.never advanced to unsupervised status. 135 The foregoing evidence amply supports the trialcourt's finding that respondent was unfit because shefailed to make substantial progress toward the returnof R.L. to her custody within the time periods allegedin the petition. We specifically note that, althoughMcAfee testified that, at the time of the fitness portionof the termination proceedings, respondent had beenapproved for a parenting capacity assessment due torecent progress in cooperation and substance abuseservices, she still had not completed counseling oranger management classes. McAfee also testified thatshe made the referral to “plan for two differentoutcomes.” 136 We note that respondent specifically arguesthat “[her] progress was undermined by agencyfailures, not parental indifference,” alleging that shewas “denied mental health services at Memorial”and “turned away from Survivor Recovery due towaitlists.” The evidence establishes, however, thatthese delays were caused by respondent herself, notthe agency. The agency offered respondent a newcounselor when her first counselor left, but respondentrejected that offer and opted to find one on her own anddid not do so promptly, resulting in several months ofdelay until the agency intervened. 137 Respondent also alleges that shereported transportation barriers, work conflicts,and inconsistent communication from caseworkers.However, Beck testified that the agency offeredrespondent bus passes, which she declined.Additionally, respondent never provided Beck with awork schedule so Beck could avoid work conflicts, andrespondent testified that she only “recently” had begunproviding her work schedule to McAfee. Beck testifiedthat she communicated with respondent weekly andmet with respondent more than she did with other
In re R.L., Not Reported in N.E. Rptr. (2025)2025 IL App (4th) 241211-U © 2025 Thomson Reuters. No claim to original U.S. Government Works.14parents in an effort to get respondent to engage so shecould have R.L. returned to her care.*15 138 For these reasons, we emphaticallyreject respondent's assertions that DCFS (1) “set[respondent] up to fail” and (2) “failed to makereasonable efforts to facilitate reunification.” 139 Last, respondent argues that “the trial court reliedon speculative concerns about a relationship [withMalcolm] without affording a path to reunification.”We initially note that respondent provides no authorityfor the proposition that the trial court cannot considera paramour's need for services as part of its unfitnessfinding. Respondent asserts that “[t]ermination basedupon the fear of a hypothetical risk is not permittedunder Illinois law,” but the case cited for thatproposition, In re C.P., 2018 IL App (4th) 180378, doesnot exist. 140 Even if such authority existed, the riskMalcolm posed to R.L. was not speculative orhypothetical. We point specifically to the November2023 incident, during which, according to respondent'sown testimony, he was drinking and hit her in theface and then chased her with an axe after she hithim back. She also testified that she believed he lastdrank four months before the termination proceedingsand she had smoked marijuana with him a “coupledays” before her testimony. Because respondent wasin a relationship with Malcolm, he was requiredto complete services as part of R.L.’s reunificationprocess. However, respondent hid her relationship withMalcolm from her caseworker and service providersfor several months, delaying that process. And evenafter it was discovered, McAfee testified that hehad not completed any domestic violence or angermanagement courses, although she had “laid out thethings he [could] get started on.” 141 Accordingly, we affirm the trial court's findingthat respondent was unfit. 142 D. The Trial Court's Best Interest Finding 143 1. The Applicable Law and Standard of Review 144 At the best interest stage of a terminationproceeding, the State bears the burden of proving bya preponderance of the evidence that termination ofparental rights is in the child's best interest. In re C.P.,2019 IL App (4th) 190420, 71. In reaching a bestinterest determination, the trial court must consider,within the context of the child's age and developmentalneeds, the following factors:“(1) the child's physical safety and welfare; (2) thedevelopment of the child's identity; (3) the child'sfamilial, cultural[,] and religious background andties; (4) the child's sense of attachments, includinglove, security, familiarity, continuity of affection,and the least disruptive placement alternative; (5)the child's wishes and long-term goals; (6) the child'scommunity ties; (7) the child's need for permanence,including the need for stability and continuity ofrelationships with parent figures and siblings; (8) theuniqueness of every family and child; (9) the risksrelated to substitute care; and (10) the preferences ofthe person available to care for the child.” (Internalquotation marks omitted.) In re J.B., 2019 IL App(4th) 190537, 32.See 705 ILCS 405/1-3(4.05) (West 2024). 145 A reviewing court affords great deference toa trial court's best interest finding because the trialcourt is in a superior position to view the witnessesand judge their credibility. C.P., 2019 IL App (4th)190420, 71. An appellate court “will not disturb thetrial court's decision regarding a child's best interests*** unless it is against the manifest weight of theevidence.” Id. 68. A best interest determination isagainst the manifest weight of the evidence only whenthe opposite conclusion is clearly the proper result. Id. 146 2. This Case*16 147 The evidence in this case also supports thetrial court's finding that it was in R.L.’s best interest toterminate respondent's parental rights. 148 R.L. was 16 months old when she was taken intocare in November 2021 and has lived in the same fosterhome ever since. Her foster parents wish to adopt her.She has developed a “strong and secure” bond withthem and calls them “[m]om and dad.” R.L. has also
In re R.L., Not Reported in N.E. Rptr. (2025)2025 IL App (4th) 241211-U © 2025 Thomson Reuters. No claim to original U.S. Government Works.15developed a “very close” bond with her foster sister, aswell as her foster parents’ extended family, calling herfoster grandparents “Gigi and Papa.” 149 R.L.’s foster parents provide for her emotionalneeds. McAfee testified that she “looks to them in*** her moments of chaos for some peace.” Theyalso provide for her developmental needs. Whenshe entered foster care, R.L. was unable to walkor communicate and was “very delayed,” displayingdevelopmental and behavioral delays. Her fosterparents have taken her to occupational and speechtherapy, as well as her pediatrician appointments. Theyalso provide for her educational needs, having enrolledher in a pre-K program. In her foster parents’ care, R.L.has “consistently improv[ed],” and “she just keepsexcelling [beyond] everyone's expectations.” 150 On the other hand, although R.L. has appearedto enjoy the time she has spent with respondent,she only recently began talking about her, callingher “new mommy.” Throughout the case, respondentdemonstrated an inability to be on time for visits,appointments, and even the termination proceedings.We do not doubt respondent loves her daughter andbelieves she can provide for her daughter's specialneeds, but the evidence establishes that R.L.’s needswill be best served living in the stable, reliable home ofher foster parents with the permanency that terminationof respondent's parental rights provides. 151 For the foregoing reasons, we conclude that theevidence supports the trial court's finding that it is inR.L.’s best interest to terminate respondent's parentalrights. 152 As a final point, we recognize that respondentspecifically argues that “the [trial] court failed toconsider less restrictive permanency alternatives,”asserting that the trial court “was required toconsider alternatives to permanent severance, such assubsidized guardianship.” However, respondent againfails to cite any authority standing for this proposition.Respondent cites only In re K.E.S., 347 Ill. App. 3d452, 457 (2004), a proceeding under section 11-5(b)of the Probate Act (755 ILCS 5/11-5(b) (West 2002)),in which the natural mother petitioned to terminatethe guardianship of her children by their uncle. Theappellate court affirmed the trial court's denial of themother's petition. K.E.S., 347 Ill. App. 3d at 463. K.E.S.does not even come close to supporting respondent'sargument in this case. 153 E. Due Process 154 Respondent also claims that “the terminationproceeding was fundamentally unfair,” arguing thatshe was denied a “fair and meaningful opportunityto preserve her parental rights” because she was“denied unsupervised visits, blocked from home-basedreunification, and evaluated through the lens of a rigidagency perspective, not a holistic or child-centeredlens.” The evidence is to the contrary.*17 155 Respondent failed to advance tounsupervised visits because of her own failure toprogress in services and pass a home safety check.She concealed her relationship with Malcolm, whichinvolved domestic violence and substance abuse,creating valid concerns about R.L.’s well-being withMalcolm in respondent's home. Likewise, the state ofrespondent's home created valid concerns for R.L.’ssafety if left unsupervised in R.L.’s home. Further, theevidence demonstrates that R.L.’s caseworkers and thetrial court operated in this case based on R.L.’s bestinterest. 156 Accordingly, we reject respondent's conclusoryassertion that the termination proceedings werefundamentally unfair. 157 We thank the trial court for its carefulconsideration of the circumstances of this case and itsdetailed discussion of its findings, which this courtfound helpful to the resolution of this appeal. 158 III. CONCLUSION 159 For the reasons stated, we affirm the trial court'sjudgment. 160 Affirmed.
In re R.L., Not Reported in N.E. Rptr. (2025)2025 IL App (4th) 241211-U © 2025 Thomson Reuters. No claim to original U.S. Government Works.16Justices Zenoff and DeArmond concurred in thejudgment.All CitationsNot Reported in N.E. Rptr., 2025 IL App (4th) 241211-U, 2025 WL 2413284End of Document© 2025 Thomson Reuters. No claim to original U.S.Government Works.
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