In re G.J.

2023 IL App (5th) 230497-U
CourtAppellate Court of Illinois
DecidedNovember 28, 2023
Docket5-23-0497
StatusUnpublished

This text of 2023 IL App (5th) 230497-U (In re G.J.) 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 G.J., 2023 IL App (5th) 230497-U (Ill. Ct. App. 2023).

Opinion

2023 IL App (5th) 230497-U NOTICE NOTICE Decision filed 11/28/23. The This order was filed under text of this decision may be NOS. 5-23-0497, 5-23-0498, 5-23-0499 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 G.J., D.H., and R.H., Minors ) Appeal from the ) Circuit Court of (The People of the State of Illinois, ) Edgar County. ) Petitioner-Appellee, ) ) v. ) Nos. 20-JA-10, 20-JA-11, 20-JA-12 ) A.H., ) Honorable ) Matthew L. Sullivan, Respondent-Appellant). ) Judge, presiding. ______________________________________________________________________________

JUSTICE CATES delivered the judgment of the court. Presiding Justice Boie and Justice Vaughan concurred in the judgment.

ORDER

¶1 Held: The circuit court’s fitness determination was not against the manifest weight of the evidence. The lack of factual findings by the circuit court precluded review of whether it was in the children’s best interest to terminate Mother’s parental rights and the trial court’s order is reversed where the trial court failed to consider the relevant statutory factors.

¶2 The respondent, A.H. (Mother), appeals from the circuit court’s January 19, 2023, decision

to terminate her parental rights and the June 27, 2023, order denying her motion to reconsider. For

the reasons set forth below, we reverse and remand this cause for further proceedings.

¶3 I. BACKGROUND

¶4 Mother is the biological mother of G.J., born on July 13, 2015, D.H., born on December

20, 2017, and R.H., born on June 16, 2020. Mother was reported to the Illinois Department of

1 Children and Family Services (DCFS) because Mother and R.H. tested positive for

methamphetamine at R.H.’s birth. Due to Mother’s methamphetamine use, the three children were

taken into DCFS custody.

¶5 On June 19, 2020, the State filed juvenile petitions for G.J., D.H., and R.H. pursuant to the

Juvenile Court Act of 1987 (705 ILCS 405/2-3(1) (West 2018)) based on neglect due to an

injurious environment. The petition filed for R.H. alleged that Mother had repeatedly used

methamphetamines and R.H. tested positive for methamphetamines on June 16, 2020, his date of

birth. The petitions filed for G.J. and D.H. were substantially similar. Both petitions included

neglect allegations that Mother repeatedly used methamphetamines, their sibling, R.H., testing

positive for methamphetamines at birth, and Mother had left the children unsupervised at times.

¶6 DCFS created a Family Service Plan on July 22, 2020, with the goal of having the children

return home within 12 months. The service plan required that Mother complete an integrated

assessment (IA), engage in substance abuse treatment, and demonstrate progress with that

treatment. After Mother completed the IA, her service plan was updated to include individual

psychotherapy, and domestic violence education, as well as substance abuse treatment.

¶7 Mother successfully completed substance abuse treatment in October of 2020, through the

Human Resource Center (HRC) in Paris, Illinois. Random drug screens remained as a service

requirement to monitor Mother’s sobriety.

¶8 Mother admitted to the allegations in the juvenile petitions, and an order of adjudication

was entered on March 4, 2021. Approximately one month after the adjudication order was entered,

Mother tested positive for methamphetamines, and was required to reengage with substance abuse

treatment through HRC.

2 ¶9 The circuit court entered a dispositional order on August 12, 2021, finding that it was in

the best interests of the children that they be made wards of the court. Mother was found unfit or

unable to parent the children. DCFS received custody and guardianship.

¶ 10 On August 3, 2022, the State filed motions to terminate parental rights for each of the

children. The State claimed that Mother’s parental rights should be terminated because she failed

to maintain a reasonable degree of interest, concern, or responsibility as to her children’s welfare,

and she failed to make reasonable progress toward the return of her children within nine months

after adjudication of neglect. The motion did not specify the nine-month time period when Mother

had not made reasonable progress.

¶ 11 The hearing on the termination of parental rights took place on January 19, 2023. Mother

requested a continuance and argued that she was told the day before the trial that she had tested

positive for illegal substances. Mother wished to challenge the results of the drug test through a

hair follicle sample test. The continuance was denied, and the circuit court proceeded with the

fitness hearing.

¶ 12 Morgan Kent, a child welfare advanced specialist with DCFS, was the only witness to

testify during the fitness hearing. Kent was assigned as the caseworker in this matter in July of

2020, and she remained as the caseworker through the date of the hearing. According to Kent,

during the time frame of March of 2021 to December of 2021, Mother was required to complete

substance abuse treatment, individual therapy, a psychiatric assessment, and domestic violence

counseling. Kent clarified that the domestic violence requirement was a component of her

individual therapy sessions.

¶ 13 Kent testified that Mother completed substance abuse treatment in October of 2020,

through HRC. Mother subsequently tested positive for methamphetamines in April of 2021. Due

3 to that relapse, Mother was required to reengage in substance abuse services. Mother restarted

treatment in September of 2021. Mother missed a drug test screen in September of 2021, and she

refused a drug test in November of 2021. Consequently, Mother did not complete substance abuse

treatment during the time frame of March 2021 to December 2021.

¶ 14 During the time period from December of 2021 to August of 2022, Mother was engaged

in treatment at HRC. Kent requested that Mother complete three drug screens during that time

period, and Mother did not comply with Kent’s requests. Mother did, however, complete multiple

drug screens through HRC, and those tests were negative. Kent testified that Mother had a positive

drug screen in December of 2022.

¶ 15 Kent testified that Mother never completed individual therapy or domestic violence

requirements. Mother was discharged from therapy services in June of 2021, for failing to attend.

Mother reengaged in individual therapy in January of 2022, but she continued to miss sessions and

was discharged again. Mother was under the impression that she completed the individual therapy

requirement during her substance abuse therapy. Kent addressed this issue and during her

conversation with Mother, Kent clarified that the individual therapy requirement was separate from

substance abuse therapy. According to Kent, Mother reengaged in individual therapy in November

of 2022, and she completed a psychiatric evaluation in December of 2022.

¶ 16 On cross-examination, Kent testified that during the time period of December 2021 to

August of 2022, Mother had not been discharged from HRC for lack of attendance. Mother was

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2023 IL App (5th) 230497-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-gj-illappct-2023.