NOTICE 2025 IL App (4th) 250755-U FILED This Order was filed under December 2, 2025 Supreme Court Rule 23 and is NO. 4-25-0755 Carla Bender not precedent except in the 4th District Appellate limited circumstances allowed IN THE APPELLATE COURT Court, IL under Rule 23(e)(1). OF ILLINOIS
FOURTH DISTRICT
In re A.T., a Minor ) Appeal from the ) Circuit Court of (The People of the State of Illinois, ) Peoria County Petitioner-Appellee, ) No. 23JA257 v. ) Dashaina W., ) Honorable Respondent-Appellant). ) David A. Brown, ) Judge Presiding.
JUSTICE STEIGMANN delivered the judgment of the court. Justices Lannerd and DeArmond concurred in the judgment.
ORDER
¶1 Held: The appellate court concluded that the trial court’s decision to terminate the wardship of the minor at issue in this case was not against the manifest weight of the evidence.
¶2 Respondent, Dashaina W., is the mother of A.T. (born January 2023). In
November 2023, the State filed a petition alleging A.T. was a neglected minor pursuant to
section 2-3(1)(a)(b) of the Juvenile Court Act of 1987 (Act) (705 ILCS 405/2-3(1)(a)(b) (West
2022)).
¶3 In November 2023, the trial court placed temporary custody and guardianship of
A.T. with the guardian administrator of the Illinois Department of Children and Family Services
(DCFS) and also entered a protective order requiring A.T. to reside with her father, Dammion T.,
and prohibiting respondent from having unsupervised contact with A.T. In March 2024, the trial court adjudicated A.T. a ward of the court, placed custody and guardianship of A.T. with
Dammion, and found respondent unfit due to medical neglect and domestic violence.
¶4 In July 2025, the trial court found that wardship was no longer in A.T.’s best
interests and the closure of the case was appropriate. The court confirmed that respondent
remained unfit, Dammion remained fit, and permanency had been achieved with Dammion as
A.T.’s sole guardian and custodian.
¶5 Respondent appeals, arguing the trial court erred when it (1) terminated A.T.’s
wardship and closed the juvenile case, finding wardship was no longer in the child’s best
interests, and (2) entered a permanency order that failed to comply with the statutory written-
finding requirement. We affirm.
¶6 I. BACKGROUND
¶7 A. The Neglect Petition and Temporary Custody Order
¶8 In November 2023, the State filed a petition alleging that A.T. was a neglected
minor pursuant to section 2-3(1)(a)(b) of the Act (705 ILCS 405/2-3(1)(a)(b) (West 2022)). The
petition alleged A.T. was neglected because she was not receiving the care necessary for her
well-being due to respondent’s medical neglect. Specifically, the petition alleged that A.T. was
hospitalized twice due to respondent’s failure to properly care for her severe eczema. The
petition also alleged that during both hospitalizations, respondent initiated physical altercations
with Dammion. The State also requested an order (1) directing that A.T. reside with her father,
(2) prohibiting respondent from residing with A.T., and (3) limiting respondent’s contact with
A.T. to DCFS-supervised visits.
¶9 Later that month, following a hearing, the trial court entered an order finding
probable cause to believe the allegations in the State’s neglect petition were true. The court
-2- ordered both parents to cooperate with DCFS and also entered an order of protection, which
provided that (1) A.T. was to reside with Dammion, (2) respondent was prohibited from being
present in the minor’s residence, and (3) respondent was to have no contact with A.T. unless it
was directly supervised by DCFS or its designee.
¶ 10 B. The March 2024 Adjudicatory Hearing and Dispositional Hearing
¶ 11 In March 2024, the trial court conducted an adjudicatory hearing, which was
immediately followed by a dispositional hearing.
¶ 12 1. The Adjudicatory Hearing
¶ 13 At the outset of the adjudicatory hearing, the parties stipulated to the allegations
in the State's neglect petition. The State then provided the following factual basis for the
stipulations:
“[F]or Count 1(a)(1)—for Count 1(a) in general, I would proffer several medical
records from Carle Health, OSF, and Loyola Hospital. The Carle Health medical
records would establish August 28th of 2023[,] the minor was admitted to Carle
Health. Severe eczema were noted on the minor’s face, and the minor had high
fever. The minor was later transferred to OSF for escalation of care, and due to
her getting worse, the child was later transferred to Loyola Hospital about
September 5th of last year. And the child was discharged from Loyola for three
days with detailed instructions.
And in [the] August admission by Carle Health, the medical records
established the child had possible nutritional deficiency, and the mother—the
medical records noted the mother didn’t feed the child with sufficient solid foods,
only milk through the bottle. And Carle Health medical record also reflect that
-3- when the medical staff was discussing with mother about the possible feeding,
and the mother was looking at her phone, and the treating doctor noted there were
concerns.
For Count 1(a)(2) I would proffer the DCFS investigator, Katrina
Dickerson (phonetic), she spoke with respondent father on about October 6th of
last year, and the father reported that when the child was admitted to the hospital,
he came to visit and had argument with respondent mother and [she] ended up
breaking his phone.
For Count 1(b)(1) I would proffer the medical records from OSF. The
child was admitted to OSF in October 6th about last year by the respondent father,
and respondent father would testify for three days before the mother dropped off
the child without giving him further information on how to take care of the child’s
skin. And the father would also testify they were fighting about the custody.
For Count 1(b)(2) I would proffer the medical records from OSF to show
the child’s detailed medical conditions.
For Count 1(b)(3) I would proffer the OSF medical records. Medical
record would reflect on October 8th of 2023[,] the nurses were hearing the
arguments from the minor’s room, and they were observe the minor’s sheets and
the pillows were covered with blood. When the nurse Ms. McNile (phonetic) was
looking into that, she observed the arm splints and other equipment were
removed. And she educated the mother, but the mother didn’t respond at that
point.
For Count 1(b)(4) I would proffer the minor’s medical records from OSF.
-4- October 8th of 2023, the notating nurses heard arguments from the patient’s room,
and the respondent father requested removing the mother. And the police—Peoria
Police Officer Steven Miller responded, and several OSF security officers
responded. They spoke with the father. He reported the details, what happened,
and the—basically, the father took the respondent mother, threw the phone on the
ground, and threw his glasses—no—sorry. Excuse me—threw his glasses on the
ground and struck him in the face, and respondent mother was removed from the
room.
For count 1(b)(5) the medical record would reflect the mother came back
after the October 8th of 2023 incident. She was not allowed in, and she tried to
discharge the minor. She was asked to leave the hospital as the DCFS open
investigation.”
¶ 14 The trial court accepted the State’s proffer and found an adequate factual basis for
the parents’ stipulations. The court then found the State had met its burden of proof, determining
that the material allegations in the petition were true and that A.T. was a neglected minor subject
to an environment injurious to her welfare due to medical neglect and domestic violence.
¶ 15 2. The Dispositional Hearing
¶ 16 Immediately thereafter, the trial court then conducted a dispositional hearing, at
which it considered, among other things, a dispositional report filed ahead of the March 7, 2024,
hearing.
¶ 17 The report detailed new incidents involving respondent on December 23, 2023.
On that day, respondent, accompanied by a police officer and others, went to Dammion’s
residence and claimed she was entitled to take A.T., despite a court order limiting her to
-5- supervised contact. The officer, unaware of the court order, instructed the paternal grandmother
to release A.T. to respondent. When respondent returned A.T. later that day, she allegedly
assaulted the grandmother as she was holding A.T. This incident resulted in an indicated finding
against respondent for creating a substantial risk of physical injury and an environment injurious
to A.T.’s health.
¶ 18 Later that same day, respondent, her sister, and others went to Dammion’s
workplace and became involved in another physical altercation. During the incident, respondent
threw a cup of ice at Dammion and jumped behind the counter to fight him. Respondent was
later arrested for domestic battery as a result.
¶ 19 The report also noted that although respondent maintained appropriate housing,
part-time employment, and communication with DCFS, she had not yet completed a required
mental health assessment. She began anger management classes and parenting classes on
February 21, 2024. Her supervised visits, conducted initially at the DCFS office and later at her
home, were reported as positive. The report stated Dammion was cooperative, employed full-
time, and capable of meeting A.T.’s needs. A.T., who was residing with Damion, was thriving in
his care, and her medical condition was under control.
¶ 20 After hearing the parties’ recommendations, the trial court entered a written
dispositional order (1) making A.T. a ward of the court, (2) finding respondent unfit for reasons
other than financial circumstances alone to protect, care for, train, or discipline the minor, and
(3) placing custody and guardianship of A.T. with Dammion, whom the court found fit.
¶ 21 The trial court ordered both parents to cooperate with DCFS, comply with their
service plans, and correct the conditions requiring the child to be in care or risk the termination
of their parental rights. The court also ordered that the existing order of protection, which
-6- required respondent’s visits to be supervised by DCFS, remain in place.
¶ 22 The trial court’s dispositional order specifically required respondent to (1) submit
to a mental health assessment and follow all recommendations, (2) successfully complete
parenting, domestic violence, and anger management courses, (3) obtain and maintain stable,
safe housing, (4) notify DCFS within three days of any change in address, phone number, or
household members, (5) provide DCFS with information about new individuals who may affect
the children, and (6) make her best efforts to obtain and maintain a legal source of income.
¶ 23 The trial court set a six-month permanency review hearing for September 5, 2024,
stating the focus would be on respondent’s “efforts and progress” and warning her that she did
“not *** have an unlimited amount of time to make some changes.”
¶ 24 C. The September 2024 Permanency Review Hearing and Order
¶ 25 In September 2024, the trial court conducted a permanency review hearing, at
which it considered a DCFS report dated September 3, 2024, and police incident reports. The
State had filed police reports documenting (1) respondent’s arrest for the December 2023
domestic battery, (2) an April 2024 weapons citation, where she was found in possession of brass
knuckles, and (3) an April 2024 runaway report for a family member.
¶ 26 The DCFS report noted that since the dispositional hearing, respondent completed
a mental health assessment in May 2024, which resulted in no recommendations or referrals for
mental health treatment. She began anger management classes in February 2024 and successfully
completed the program in April 2024. She also began parenting classes in February 2024 and had
since successfully completed them. However, respondent’s attendance at domestic violence
counseling, which began in June 2024, was inconsistent; the provider reported respondent had
missed as many classes as she had attended and risked an unsuccessful discharge if she missed
-7- another class.
¶ 27 The report described A.T., then one year old, as thriving in Dammion’s care, with
her eczema under control. Caseworkers observed that A.T. had a strong attachment to her father
and affectionate interactions with him during visits. The caseworker who authored the report
noted that respondent had improved her communication with Dammion and had completed
parenting and anger management services, but she still needed to finish domestic violence
services.
¶ 28 At the permanency review hearing, the State, the guardian ad litem (GAL), and
respondent’s attorney all recommended keeping the case open, while Dammion’s attorney
argued for immediate closure, expressing concern that respondent’s missed appointments for her
domestic violence class would result in her being kicked out. Dammion’s attorney argued that
Dammion and A.T. “should [not] have to wait” for that process.
¶ 29 Following the parties’ recommendations, the trial court stated that DCFS and
Dammion had made reasonable efforts. However, it characterized respondent’s efforts as mixed
but “overall reasonable.” Despite Dammion’s request to close the case, the court left the case
open to monitor respondent’s completion of the domestic violence program and avoidance of any
further police contact. The court emphasized the case “should be all about *** making some
changes,” and the “biggest change” it wanted to see was respondent not continuing “to get into
issues with the police.” The court warned respondent that a child does not understand such
events the way an adult does and stressed that the “trauma that’s inflicted on them” is what
matters, not excuses for the police encounters. Ultimately, in its written order, the court found
Dammion remained fit and respondent remained unfit. The court ordered a permanency goal of
“remain intact.”
-8- ¶ 30 D. The February 2025 Permanency Review Hearing and Order
¶ 31 In February 2025, the trial court conducted a permanency review hearing, at
which it considered a January 2025 DCFS report, testimony, and police reports dated October
22, 2024, and January 26, 2025.
¶ 32 The DCFS permanency report provided updates since the September 2024
permanency review hearing. The report noted respondent was employed by Amazon. In
November 2024, she reported she was pregnant and wanted to regain fitness. In December, she
informed the caseworker she had miscarried, but she remained intent on working toward
regaining fitness.
¶ 33 The report also documented significant new legal issues. Respondent had a new
arrest in October 2024 for domestic battery, criminal damage to property, and interference with
reporting. A warrant was subsequently issued in December 2024 for her failure to appear.
Furthermore, the probation department reported that a petition to revoke respondent’s
supervision (from a prior matter) had been filed in January 2024, alleging a subsequent arrest and
unpaid fines.
¶ 34 Regarding respondent’s progress in services, she was unsuccessfully discharged
from her initial domestic violence program in September 2024 for multiple absences and rule
violations. She was referred to a new six-month program at the Center for Prevention of Abuse,
which she began attending weekly in December 2024. The new provider reported she had been
cooperative, with no issues.
¶ 35 Dammion remained cooperative and had no recommended services; he
transported A.T. to school, communicated with staff, and handled medical appointments. A.T.
continued to reside with Dammion, was still thriving, and was up to date on her immunizations,
-9- with no concerns noted at her November 2024 medical visit.
¶ 36 The January 2025 police report detailed an incident in which the police responded
to a reported domestic dispute involving respondent. Her ex-boyfriend reported that she had
taken his video game consoles after an argument. Officers observed both parties yelling at each
other. The consoles were found in respondent’s vehicle and returned. During the encounter,
officers documented that respondent made suicidal statements, and emergency response services
were called to meet with her.
¶ 37 The trial court found the “intact” permanency goal appropriate, determining that
(1) the required services were appropriate and had been provided and (2) A.T.’s placement was
necessary and appropriate to the service plan and goal. Over Dammion’s request to close the
case, the court kept the matter open to give respondent an opportunity to work toward restoring
her fitness.
¶ 38 E. The July 2025 Permanency Review Hearing and Order
¶ 39 In July 2025, the trial court conducted the final permanency review hearing in this
case, at which the court considered testimony, a July 2025 DCFS permanency report, and a
police report dated July 9, 2025.
¶ 40 The DCFS report stated that respondent resided in a one-bedroom apartment, was
employed, and maintained communication with the caseworker. The report stated respondent had
completed all her services, including parenting classes (completed in February 2024), anger
management services (completed in April 2024), and a 26-week domestic violence intervention
program (completed in June 2025). Respondent had also attended two-hour supervised visits
with A.T. at the DCFS office, which went well.
¶ 41 In its assessment, DCFS noted the case has been open since December 2023.
- 10 - Dammion was cooperative, provided a “stable living environment,” and ensured all A.T.’s needs
were met. The report noted Dammion and respondent “have been getting along” and he had been
updating her on A.T.’s schooling and medical needs.
¶ 42 Although the report noted that respondent had no new incidents involving law
enforcement since October 2024, respondent was arrested for domestic battery on July 9, 2025,
just two days before the hearing, which was set forth in the July 2025 police report the State
filed. According to the report, on July 9, 2025, police officers responded to a disturbance
involving respondent and her then-boyfriend, Carl Parker, at Parker’s sister’s house. Parker and
an eyewitness reported that respondent pulled her car in front of the house and sprayed Parker
with pepper spray. Recorded video from a doorbell security camera showed Parker running
inside holding his face, with respondent later attempting to enter the home.
¶ 43 During the hearing, respondent testified that she had been in a relationship with
Parker from February 2025 until the July 2025 incident. She acknowledged her caseworker was
unaware of this relationship. Regarding the incident, respondent testified that she sprayed Parker
in self-defense after he allegedly pushed and punched her. She also testified that she was
pursuing an order of protection against Parker.
¶ 44 The State, GAL, and Dammion’s attorney recommended that the case be closed
and Dammion be made sole guardian. Conversely, respondent’s counsel asked to keep the case
open for one more reporting period, arguing respondent had done what she had been ordered to
do and needed extra counseling to “turn the corner” on these issues.
¶ 45 The trial court ordered the case closed, finding that Dammion remained fit and
respondent unfit. When doing so, the court stated the following:
“The Court would find that DCFS has made reasonable efforts. It’s an
- 11 - intact case with dad. No efforts findings are necessary for him, but he’s done
what’s been asked of him.
Mom, I don’t know that there’s much I can or need to add, but just from a
historical standpoint, there has been continued police contact and arrests due to
violence among family members and/or household members or dating
relationship people really for the last two years involving you. Every—almost
every report that—and reporting period we have[ ]—even the couple of months
leading up to the disposition, there were family fights and police being called.
And services have been provided included anger management, domestic violence,
counseling for two years, and we continue to have the same conduct. And
whose fault it is at this stage of the game as far as one particular altercation or
interaction, whether it was the boyfriend’s fault or mom’s fault, it’s really kind of
beside the point at this stage of the game. It’s the fact that we can’t—you can’t
change your life so that this violence and police contact and arrests aren’t a
constant part of—or almost constant part of it. Services have been provided.
Resources have been allocated that—and that keeps coming back up.
And so dad’s fit. He’s remained fit the whole time. The child is safe and
secure with dad. Mom remains unfit. I believe dad’s attorney has asked that the
case be closed for the last ten months repeatedly at each review period, and it’s
been declined so that mom could finish up services and make some changes.
She’s finished up the services, but she hasn’t made the changes.
I don’t—it’s not reasonable for me to project into the future that that’s
going to change at this point in time. We’ll repeat some services. And it’s
- 12 - unfortunate. And it’s not going to be convenient for dad or for [A.T.] that we
close out the case with mom remaining unfit, but I think that’s in the child’s best
interest.
Mom, you can continue on your journey to try to get this stuff sorted out,
but I don’t think it’s in the public’s best interest to continue to dedicate scarce
resources that other families are in need of for a mom who’s not willing to or able
to make some changes and to eliminate domestic violence and violence from her
life.
And so, I agree with the recommendation to close the case out today with
guardianship and custody to dad. Mom remaining unfit.”
¶ 46 Following the hearing, the trial court issued a permanency review order, finding
that permanency had been achieved through intact services and it was in A.T.’s best interests to
close the case. The court granted Dammion sole guardianship and custody of A.T. and ordered
the wardship terminated and the case closed, finding that respondent remained unfit.
¶ 47 The trial court entered a written “Order For Case Closure & Termination of
Wardship” (1) closing the cause because “the health, safety, and best interests of [A.T.] and the
public no longer require[d]” A.T.’s wardship, (2) finding that respondent remained unfit, and
(3) naming Dammion “sole guardian & custodian of [A.T.]”
¶ 48 This appeal followed.
¶ 49 II. ANALYSIS
¶ 50 Respondent appeals, arguing the trial court erred when it (1) terminated A.T.’s
wardship and closed the juvenile case, finding wardship was no longer in A.T.’s best interests
and (2) entered a permanency order that failed to comply with the statutory requirement that the
- 13 - court make written findings supporting its conclusions. We affirm.
¶ 51 A. Termination of Wardship and Closing the Case
¶ 52 Respondent asserts that the trial court erred by finding that the minor’s best
interests no longer required wardship and that this matter should not be closed. We disagree.
¶ 53 1. The Applicable Law and Standard of Review
¶ 54 Section 2-31(2) of the Act provides the following regarding the termination of
wardship:
“Whenever the court determines, and makes written factual findings, that health,
safety, and the best interests of the minor and the public no longer require the
wardship of the court, the court shall order the wardship terminated and all
proceedings under this Act respecting that minor finally closed and discharged.
The court may at the same time continue or terminate any custodianship or
guardianship theretofore ordered but the termination must be made in compliance
with Section 2-28.” 705 ILCS 405/2-31(2) (West 2024).
¶ 55 When determining a child’s best interests under the Act, a trial court “must
evaluate the minor’s physical safety and welfare, the development of his identity, his background
and ties, his sense of attachments, his wishes and long-term goals, his community ties, his need
for permanence, and the preferences of the persons available to care for him.” In re Aaron R.,
387 Ill. App. 3d 1130, 1138 (2009); see 705 ILCS 405/1-3(4.05) (West 2024).
¶ 56 “A court’s termination of wardship is reviewed under a manifest-weight-of-the-
evidence standard when the court’s weighing of facts is at issue. [Citation.] A judgment is
against the manifest weight of the evidence when the opposite conclusion is clearly
apparent.” In re M.H., 2025 IL App (4th) 250271, ¶ 26.
- 14 - ¶ 57 2. This Case
¶ 58 Respondent argues that the trial court’s finding that wardship was no longer
required was against the manifest weight of the evidence. She asserts that the July 2025 DCFS
report documented that she (1) had completed every ordered service, including a 26-week
domestic-violence program, (2) had corrected her earlier visitation issues, and (3) was engaging
appropriately with A.T. She also claims that the court placed too much reliance on the July 2025
incident days earlier between her and her boyfriend, which involved “competing accounts” of
what occurred. According to respondent, this evidence made the opposite conclusion clearly
apparent—namely, that A.T.’s best interests were served by continuing wardship.
¶ 59 Although respondent frames her argument as merely “a short period of ongoing
wardship (at minimal burden) to verify whether [her] freshly completed services translated into
lasting change,” her argument ignores the record. The record shows that the trial court had
already given respondent ample opportunity to regain fitness for the nearly two years since this
case’s inception in November 2023. All the while, Dammion had (1) provided a stable and safe
household for A.T., (2) remained fit, and (3) required no services. In Dammion’s care, A.T. was
“thriving.” Respondent, on the other hand, had consistently brought instability into A.T.’s life, as
demonstrated by her repeated arrests and incidents of domestic violence.
¶ 60 To the extent that respondent argues that her “progress” in completing her
services should postpone the case’s closure, we emphatically reject this argument. “Progress” by
“checking off the boxes” in a service plan is meaningless when a parent’s underlying dangerous
behavior remains unchanged. See In re Ta. T., 2021 IL App (4th) 200658, ¶ 56 (“The point of
requiring parents to attend classes and engage in services is *** so parents apply what they learn
in their lives, in the real world, such that the court can be confident that the children will be safe
- 15 - in their care.” (Emphasis in original.)). Further, “consideration of a parent’s reasonable progress
[i]s irrelevant when determining if wardship termination was proper because the appropriate
standard for termination of wardship [i]s the child’s best interest, not the parent’s reasonable
progress.” M.H., 2025 IL App (4th) 250271, ¶ 22 (citing In re M.K., 271 Ill. App. 3d 820, 831-32
(1995)).
¶ 61 The evidence in this case strongly supports the trial court’s decision to terminate
A.T.’s wardship. The DCFS reports established that A.T. was thriving in her placement with
Dammion, she attended preschool, she was a “happy toddler,” and her severe eczema was under
control. Dammion provided for all her needs, was getting along with respondent, and made sure
to update respondent on A.T.’s education and medical needs.
¶ 62 In stark contrast to A.T.’s stability with Dammion, the record shows that despite
respondent’s completion of services and ostensible cooperation, her behavior remained
dangerously unchanged. The trial court was presented with a troubling and consistent pattern of
misconduct that began before the case was even filed and continued until the very eve of the
final hearing when, in July 2025—after she had completed her 26-week domestic violence
program—respondent was arrested once again for domestic battery.
¶ 63 From this evidence, the trial court reasonably concluded that respondent remained
unfit and was unlikely to regain fitness or maintain stability within a reasonable amount of time.
On the other hand, it is undisputed that A.T. had achieved permanency with Dammion and was
flourishing in his care. We conclude that the court’s resulting decision to terminate A.T.’s
wardship was not against the manifest weight of the evidence.
¶ 64 B. Compliance With the Written-Finding Requirement of the Act
¶ 65 Respondent also argues that we should remand this case with instructions for the
- 16 - trial court to modify its July 2025 permanency review order. She contends that order failed to
comply with section 2-28 of the Act (705 ILCS 405/2-28 (West 2024)) because, for the selected
permanency goal of “CASE CLOSURE,” the court merely repeated “CASE CLOSURE” in the
“reasons” line instead of providing express written findings. The State concedes the written order
did not strictly comply with the statute but argues that the court’s detailed oral findings at the
final permanency hearing, which explained its reasons for selecting the goal and ruling out
preceding goals, were sufficient to satisfy the Act. We agree with the State.
¶ 66 Respondent cites In re K.H., 313 Ill. App. 3d 675, 683 (2000), in support of her
contention that we must remand the present case for strict compliance with section 2-28 of the
Act, but she does not explain how that case requires remand on this record. The State argues that
strict compliance is not necessary here, citing In re S.E., 319 Ill. App. 3d 937, 944-45 (2001),
which distinguished and clarified this court’s decision in K.H.
¶ 67 In S.E., we wrote the following:
“First, this case is distinguishable from K.H., in that here, the basis for the
trial court’s decision is clearly shown by the court’s lengthy finding and remarks
on the record at the August 2000 hearing. *** Given that (1) the evidence of
record was more than sufficient to support the court’s decision and (2) the basis
for that decision is ascertainable from the record, we hold that we need not
remand this case for entry of more specific written findings.
Moreover, when the record provides an adequate basis for review of the
trial court’s ruling, the legislative intent underlying the writing requirement is not
compromised by a decision not to remand. In light of the overwhelming volume
of cases moving through the trial courts and the bare-bones support staff at the
- 17 - disposal of those courts, a court’s oral pronouncement of its ruling should be
viewed as sufficient to comply with section 2-28(2) of the Act if (1) those
pronouncements appear in the record and (2) they would constitute a sufficient
statement of the court’s findings if the court had turned to the court reporter and
requested that its oral pronouncement be typed up and printed in the form of an
order. In other words, so long as something exists in the record stating the basis
for the court’s determination, the writing requirement should be deemed satisfied,
regardless of whether the ‘writing’ was prepared by the court reporter or the
court’s administrative staff.
In conclusion, we decline to remand respondent’s cause for the entry of a
written order in compliance with section 2-28(2) of the Act because the basis for
the court’s decision is readily ascertainable from the record.” Id.
¶ 68 Here, just as in S.E., the trial court provided a thorough and comprehensive oral
explanation for the change in A.T.’s permanency goal to “CASE CLOSURE” at the final
permanency review hearing (supra ¶ 45). In sum, the court described (1) an overall lack of
progress on respondent’s part, (2) respondent’s continued police contact and arrests due to
domestic violence, (3) respondent’s domestic violence and anger issues, (4) Dammion’s efforts
and continued cooperation with DCFS, and (5) the best interests of A.T. Accordingly, we decline
to remand this cause for the entry of a written order compliant with section 2-28(2.3) of the Act
because the basis for the court’s decision is readily ascertainable from the record.
¶ 69 III. CONCLUSION
¶ 70 For the reasons stated, we affirm the trial court’s judgment.
¶ 71 Affirmed.
- 18 -