In re A.I.

2022 IL App (5th) 220371-U
CourtAppellate Court of Illinois
DecidedOctober 4, 2022
Docket5-22-0371
StatusUnpublished

This text of 2022 IL App (5th) 220371-U (In re A.I.) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re A.I., 2022 IL App (5th) 220371-U (Ill. Ct. App. 2022).

Opinion

2022 IL App (5th) 220371-U NOTICE NOTICE Decision filed 10/04/22. The This order was filed under text of this decision may be NOS. 5-22-0371, 5-22-0372 cons. Supreme Court Rule 23 and is changed or corrected prior to not precedent except in the the filing of a Petition for IN THE limited circumstances allowed Rehearing or the disposition of under Rule 23(e)(1). the same. APPELLATE COURT OF ILLINOIS

FIFTH DISTRICT ______________________________________________________________________________

In re A.I. JR. and L.I., Minors ) Appeal from the ) Circuit Court of (The People of the State of Illinois, ) Macon County. ) Petitioner-Appellee, ) ) v. ) Nos. 20-JA-113 & 20-JA-114 ) Sara H., ) Honorable ) Thomas E. Little, Respondent-Appellant). ) Judge, presiding. ______________________________________________________________________________

JUSTICE WELCH delivered the judgment of the court. Justices Moore and Wharton concurred in the judgment.

ORDER

¶1 Held: The trial court’s findings that the respondent mother was unfit because she failed to make reasonable efforts and progress were not against the manifest weight of the evidence. Also, the trial court’s finding that it was in the minor children’s best interests to terminate the respondent mother’s parental rights was not against the manifest weight of the evidence. Accordingly, we affirm the court’s termination of the respondent mother’s parental rights.

¶2 The respondent mother, Sara H., appeals the judgment of the circuit court of Macon County

terminating her parental rights to her minor children, A.I. and L.I. On appeal, Sara H. argues that

the court’s findings that she was an unfit parent under sections 1(D)(b), 1(D)(m)(i), and 1(D)(m)(ii)

of the Adoption Act (750 ILCS 50/1(D)(b), (m)(i), (m)(ii) (West 2020)) were against the manifest

1 weight of the evidence. She also contends that the court’s best-interest finding was against the

manifest weight of the evidence. For the reasons that follow, we affirm.

¶3 I. BACKGROUND

¶4 Sara H. and Anthony I.1 had two children, A.I., born November 2, 2018, and L.I., born

December 17, 2019. Both children were removed from the parents’ home on May 21, 2020, and

placed with a relative. On May 22, 2020, the State filed juvenile petitions, 2 alleging that the

children were neglected pursuant to section 2-3(1)(b) of the Juvenile Court Act of 1987 (Juvenile

Court Act) (705 ILCS 405/2-3(1)(b) (West 2018)) because their environment was injurious to their

welfare due to the parents’ ongoing domestic violence and substance abuse issues in the children’s

presence. The petition also alleged that the children were abused pursuant to section 2-3(2)(ii) of

the Juvenile Court Act (id. § 2-3(2)(ii)) as their parents created a substantial risk of physical injury

to them.

¶5 Also, on May 22, the Illinois Department of Children and Family Services (DCFS) filed a

shelter care report, which indicated that the police were contacted at 11:56 p.m. on May 20, about

a physical altercation between Sara H. and Anthony I. Camera footage of the altercation showed

Sara H. and Anthony I. fighting in a parking lot of a motel while holding A.I. and L.I. While

Anthony I. was attempting to get in a vehicle, Sara H. continued attacking him. During the

altercation, an unknown bystander took A.I. from Sara H. Anthony I. reported that Sara H. struck

him with a broomstick approximately 10 to 15 times. Both Sara H. and Anthony I. were arrested

and had multiple injuries from the incident.

1 Although Anthony I.’s parental rights were also terminated, he was not part of this appeal. 2 The State filed the juvenile petition for A.I. in Macon County case No. 20-JA-113, which was docketed on appeal as 5-22-0371, and a juvenile petition for L.I. in Macon County case No. 20-JA-114, which was docketed on appeal as 5-22-0372. On June 21, 2022, this court entered an order consolidating the two appeals under 5-22-0371 for all purposes. 2 ¶6 During the incident, the children appeared to be very dirty (the bystander wiped down A.I.

because he was so dirty); Anthony I. admitted to using crack before the incident; and Sara H. was

highly intoxicated and admitted to drinking but denied other drug use, even though Anthony I. said

that she was using crack. There were alcohol bottles and garbage all over the floor of the motel

room where they had been staying for the last month; they were being kicked out of the motel.

¶7 The report further indicated that DCFS had previous involvement with Anthony I. and Sara

H. regarding the same issues, domestic violence and substance abuse (intensive intact services

were opened on June 13, 2019). In December 2019, both Anthony I. and Sara H. tested positive

for cocaine. They were considered unstable and were living in a motel after being kicked out of

their previous residence for domestic violence. Although Sara H. had completed her services, the

caseworker indicated that it appeared she was going through the motions as she had relapsed

multiple times and continued to have domestic violence issues with Anthony I.

¶8 Further, on May 22, the trial court entered a temporary custody order, placing temporary

custody of the children with DCFS. On June 2, 2020, DCFS prepared a family service plan, which

indicated that the initial case was opened after the police responded to a domestic incident at the

home. Anthony I. and Sara H. were in a physical altercation, and Sara H. scratched Anthony I. on

the neck and hit him with a salsa bottle to get him away from her. Also, Anthony I. admitted to

pushing her down. They were both arrested as a result of the incident.

¶9 According to the service plan, Sara H. was required to complete the following services:

complete parenting recommendations and parenting classes; complete a substance abuse

assessment; follow all recommendations and treatment plans from the substance abuse provider;

complete random drug screens; complete a domestic violence assessment; follow all

recommendations and treatment plans from domestic violence provider; attend all appointments

3 with caseworker; keep caseworker informed of any changes in address, phone number,

employment, and household composition; obtain and maintain stable housing; complete a mental

health assessment; and follow all recommendations and treatment plans from the mental health

provider.

¶ 10 On August 12, 2020, the trial court entered an adjudicatory order, finding that the minor

children were neglected in that they were in an environment that was injurious to their welfare.

The court also found that the State had proven, by a preponderance of the evidence, the allegations

in its juvenile petition.

¶ 11 On September 11, 2020, a dispositional hearing report was filed, which indicated that Sara

H. had a bench warrant due to her failure to appear at a September 10 court hearing. Since the

DCFS case was opened, Sara H. had regularly moved, continually changed her phone number, and

was inconsistent with maintaining communication with her caseworker. On September 23, 2020,

the trial court entered a dispositional order, finding that Sara H. was unfit and unable to care for,

protect, train, educate, supervise, or discipline the minor children and that placement with her

would be contrary to the children’s health, safety, and best interests because of her substance abuse

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2022 IL App (5th) 220371-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-ai-illappct-2022.