In re G.P.

2025 IL App (4th) 241576-U
CourtAppellate Court of Illinois
DecidedMay 12, 2025
Docket4-24-1576
StatusUnpublished

This text of 2025 IL App (4th) 241576-U (In re G.P.) 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.P., 2025 IL App (4th) 241576-U (Ill. Ct. App. 2025).

Opinion

NOTICE 2025 IL App (4th) 241576-U This Order was filed under FILED May 12, 2025 Supreme Court Rule 23 and is NOS. 4-24-1576, 4-24-1577 cons. 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 G.P., a Minor ) Appeal from the ) Circuit Court of (The People of the State of Illinois, ) Sangamon County Petitioner-Appellee, ) Nos. 22JA89 v. (No. 4-24-1576) ) 22JA90 Brett P., ) Respondent-Appellant). ) ____________________________________________ ) ) In re M.P., a Minor ) ) (The People of the State of Illinois, ) Petitioner-Appellee, ) v. (No. 4-24-1577) ) Honorable Brett P., ) Karen S. Tharp, Respondent-Appellant). ) Judge Presiding.

JUSTICE STEIGMANN delivered the judgment of the court. Justices Lannerd and Knecht concurred in the judgment.

ORDER

¶ 1 Held: The appellate court affirmed the trial court’s termination of respondent’s parental rights.

¶2 Respondent, Brett P., is the father of G.P. (born September 2021) and M.P. (born

June 2020). In October 2024, in proceedings involving both children, the trial court found

respondent was an unfit parent, and in December 2024, it found termination of respondent’s

parental rights would be in the minor children’s best interests.

¶3 Respondent appeals, arguing that the trial court’s (1) unfitness and (2) best interests findings were against the manifest weight of the evidence. We disagree and affirm.

¶4 I. BACKGROUND

¶5 A. Procedural History Regarding G.P. and M.P.

¶6 In September 2021, Brenna F., G.P. and M.P.’s mother (who is not a party to this

appeal), gave birth to G.P. At the time, M.P. was about 15 months old. Brenna and G.P. both

tested positive for cocaine. Brenna admitted to using cocaine during her pregnancy and stated

that she was receiving methadone treatment. Two days later, Brenna again tested positive for

cocaine. Four days later, she tested positive for cocaine and heroin. In December 2021, the

Illinois Department of Children and Family Services (DCFS) opened an intact case and began

working with Brenna regarding her substance abuse issues. In January 2022, Brenna tested

positive for 6-monacetylmorphine, which was consistent with heroin use. In February 2022,

Brenna tested positive for opiates—morphine and methadone.

¶7 In April 2022, the State filed petitions for adjudication of wardship as to G.P. and

M.P., alleging the children were neglected in that (1) they lived in an environment injurious to

their welfare, as evidenced by respondent’s and Brenna’s “drug use,” and (2) they were not

receiving the proper care necessary for their well-being, as evidenced by Brenna’s “failure to

cooperate fully with intact services.” See 705 ILCS 405/2-3(1)(a), (b) (West 2022).

¶8 On the same day the petitions were filed, the trial court conducted a shelter care

hearing and placed temporary custody of G.P. and M.P. with the guardianship administrator of

DCFS.

¶9 In July 2022, the trial court conducted an adjudicatory hearing regarding G.P. and

M.P. The court found that the children were neglected minors as alleged in the petitions, noting,

“[G.P. was] born substance exposed, intact services for mother offered, mother did not cooperate

-2- with services.”

¶ 10 In August 2022, the trial court conducted a dispositional hearing regarding G.P.

and M.P., and at the conclusion, it entered a written order finding (1) respondent unfit for reasons

other than financial circumstances alone to care for, protect, train, educate, supervise, or

discipline the minors and (2) it was in the best interests of the minors to be made wards of the

court. The court noted that respondent and Brenna needed to cooperate with services or they

risked termination of their parental rights.

¶ 11 B. The Termination Proceedings

¶ 12 In March 2024, the State filed petitions to terminate respondent’s parental rights

as to each of the minor children. In August 2024, the State filed amended petitions. The State

alleged respondent was an unfit parent within the meaning of the Adoption Act (750 ILCS 50/1

et seq. (West 2022)) because he failed to (1) maintain a reasonable degree of interest, concern, or

responsibility as to the children’s welfare, (2) make reasonable efforts to correct the conditions

that were the bases for the children’s removal during the nine-month periods of (a) July 2022 to

April 2023, (b) April 2023 to January 2024, and (c) November 2023 to August 2024, and

(3) make reasonable progress toward the return of the children within those same nine-month

periods. See id. § 1(D)(b), (m)(i)-(ii).

¶ 13 Over two days in October and December 2024, the trial court conducted a

bifurcated termination hearing on the State’s petitions.

¶ 14 1. The Fitness Portion of the Termination Proceedings

¶ 15 In October 2024, the trial court conducted the fitness portion of the termination

proceedings. At the beginning of the hearing, the court stated that it was taking judicial notice of

the adjudicatory, dispositional, and shelter care orders.

-3- ¶ 16 a. Melissa Pease

¶ 17 Melissa Pease testified that she worked for the Family Service Center as a foster

care supervisor. In April 2023, she supervised the caseworker working on G.P.’s and M.P.’s

cases and took over the cases in June 2023. She testified that the cases first came into the system

in September 2021, when G.B. was born “substance[ ]exposed” to cocaine. Neither G.P. nor

M.P. was taken into custody at that time, but Brenna did not cooperate with DCFS, and the

children were taken into protective custody in December 2021. Respondent was arrested for a

domestic violence incident against Brenna before or around the time the minors entered care.

¶ 18 Pease testified that the service plan required respondent to engage in services

pertaining to domestic violence, anger management, substance abuse, parenting, and mental

health services. Substance abuse was the main concern for both respondent and Brenna. In

December 2021, and throughout the length of the case, both respondent and Brenna were in an

outpatient methadone treatment program, which provided them with small amounts of

methadone, an orally administered drug meant to prevent opioid withdrawal and prevent relapse.

Pease explained that the primary goal of methadone treatment was to wean the recipient off the

drug, but methadone withdrawal could be as bad if not worse than heroin withdrawal symptoms.

Both respondent and Brenna were also attending Narcotics Anonymous (NA) and Alcoholics

Anonymous (AA).

¶ 19 In April 2023, respondent was initially rated satisfactory for his engagement with

his service plan, but because he was living with Brenna, who had tested positive for illegal

substances, he was ultimately rated unsatisfactory.

¶ 20 Pease testified that in July 2023, the parents were allowed to have unsupervised

visits with the children. The daycare that G.P. went to reported to Pease that following visits with

-4- respondent and Brenna, G.P. would smell of cigarette smoke, which was concerning because

G.P. had severe allergies to cigarette smoke and exposure would require breathing treatments.

Pease testified that respondent was a smoker, but Pease noted that during random “pop-ins” to

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Bluebook (online)
2025 IL App (4th) 241576-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-gp-illappct-2025.