In re J.A.

2025 IL App (4th) 241212-U
CourtAppellate Court of Illinois
DecidedFebruary 6, 2025
Docket4-24-1212
StatusUnpublished

This text of 2025 IL App (4th) 241212-U (In re J.A.) 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 J.A., 2025 IL App (4th) 241212-U (Ill. Ct. App. 2025).

Opinion

NOTICE 2025 IL App (4th) 241212-U FILED This Order was filed under February 6, 2025 Supreme Court Rule 23 and is NO. 4-24-1212 Carla Bender not precedent except in the 4th District Appellate limited circumstances allowed under Rule 23(e)(1). IN THE APPELLATE COURT Court, IL

OF ILLINOIS

FOURTH DISTRICT

In re J.A., M.A., and S.A., Minors ) Appeal from the ) Circuit Court of (The People of the State of Illinois, ) McLean County Petitioner-Appellee, ) No. 22JA56 v. ) Sarah A., ) Honorable Respondent-Appellant). ) J. Brian Goldrick, ) Judge Presiding.

JUSTICE DOHERTY delivered the judgment of the court. Justices Zenoff and Grischow concurred in the judgment.

ORDER

¶1 Held: The trial court’s fitness and best-interest determinations were not against the manifest weight of the evidence.

¶2 In April 2024, the State filed a motion to terminate the parental rights of respondent

Sarah A. as to her minor children, S.A. (born in 2016), J.A. (born in 2012), and M.A. (born in

2009). The children’s fathers are not parties to this appeal. In September 2024, the trial court

granted the State’s petition and terminated respondent’s parental rights.

¶3 Respondent appeals, arguing the trial court’s fitness and best-interest

determinations were against the manifest weight of the evidence. We affirm.

¶4 I. BACKGROUND

¶5 In June 2022, the State filed a petition to adjudicate the children neglected under

section 2-3(1)(b) of the Juvenile Court Act of 1987 (Juvenile Court Act) (705 ILCS 405/2-3(1)(b) (West 2022)), alleging that the children were in an environment injurious to their welfare. The

State alleged (1) respondent had unresolved domestic violence and anger management issues that

created a risk of harm to the children and (2) she and the children had continuing contact with

Henry D., a person with a history of domestic violence and who respondent knew had

inappropriately touched M.A. The record shows respondent is deaf and had an interpreter at all

trial court appearances.

¶6 Respondent was not present at the hearing on the petition. The trial court considered

a report showing that, on March 24, 2022, the Illinois Department of Children and Family Services

(DCFS) received a report describing verbal and physical altercations between respondent, M.A.,

and other members of the family, including an incident where M.A. allegedly struck J.A. and

bloodied her nose.

¶7 On April 26, 2022, DCFS received a report indicating respondent suspected M.A.

might be pregnant by Henry and disclosed that she had witnessed Henry inappropriately touching

M.A. on multiple occasions. On April 27, 2022, a child protection specialist, Alexus Hobbs,

attempted to visit respondent and the children at a hotel, where respondent refused entry to their

hotel room. Hobbs noted visible bruises on respondent, who reported that Henry had recently

assaulted her. Respondent said she did not report the incident to avoid complications with an

upcoming court case. Respondent also told M.A. to tell Hobbs that Henry touched M.A.’s breast

and butt area. M.A. later confirmed the details of Henry’s conduct in an interview with the McLean

County Children’s Advocacy Center. On May 10, 2022, DCFS received a report involving a bruise

on S.A.’s arm that respondent advised S.A. to keep covered at school.

¶8 In June 2022, DCFS received additional domestic violence reports, including

allegations that respondent failed to secure an order of protection against Henry and that he still

-2- had contact with her. Respondent was subsequently unable to be located. On June 21, 2022, M.A.

was found at a friend’s home and taken into custody. J.A. and S.A. could not be located.

¶9 The trial court placed the children in the temporary custody of DCFS and issued a

warrant for the apprehension of J.A. and S.A. in order to place them in DCFS custody. On June

29, 2022, the court renewed the temporary custody order following a hearing, with respondent

present. J.A. and S.A. had been found and were in the temporary custody of DCFS. On August 24,

2022, the court adjudicated the children neglected, found respondent unfit, made the children

wards of the court, and placed guardianship and custody with DCFS.

¶ 10 On April 23, 2024, the State filed a petition for termination of parental rights,

alleging respondent was unfit under section 1(D)(m)(ii) of the Adoption Act (750 ILCS

50/1(D)(m)(ii) (West 2022)) for failing to make reasonable progress toward the return of the

children to her care during a nine-month period after the adjudication of neglect. The State alleged

one nine-month period from April 25, 2023, to January 25, 2024.

¶ 11 On September 11, 2024, the trial court held a fitness hearing. Emily Hartman, the

current caseworker on the matter, testified regarding respondent’s compliance with her service

plan. Respondent’s goals included addressing (1) mental health, (2) domestic violence,

(3) employment, (4) housing, (5) parenting, and (6) cooperation. As of April 25, 2023, referrals

had been made for all of the goals, and respondent was engaging in services through the Chicago

Hearing Society (CHS). The record shows she also engaged in services through an organization

known as Deaf Hope. The children were residing in foster care with their maternal aunt,

Jacquelyn B.

¶ 12 Shortly after April 25, 2023, the beginning of the nine-month period at issue,

respondent wrongly believed Hartman was dating respondent’s nephew, changing her name and

-3- appearance, and purposely deceiving respondent. Hartman testified she had only met respondent’s

nephew in passing. Respondent’s inaccurate beliefs made it difficult for Hartman to work with

respondent because respondent would not share information with her. Respondent continued to

believe Hartman was deceiving her, even after others intervened and provided information to show

respondent’s beliefs were inaccurate. Hartman described respondent as “coming across as very

paranoid.”

¶ 13 Respondent completed the parenting portion of her goals before April 15, 2023.

After April 25, 2023, however, she wanted an interpreter at supervised visits with the children.

Hartman’s understanding was the visits would continue while she found interpreters, but

respondent did not attend for “a couple of weeks that turned maybe into months,” until Hartman

found interpreters. Afterward, visits were inconsistent, sometimes because respondent would not

always confirm the day before, which was necessary for an interpreter to be present.

¶ 14 Hartman testified that the agency had concerns about respondent discussing

inappropriate topics during visits and not engaging with the children. Some visits were appropriate,

but the agency was concerned respondent was not exhibiting consistent parenting skills. No

progress was made on family therapy during the nine-month period. However, this was because

M.A. was not ready to engage in family therapy.

¶ 15 The trial court ordered a psychological evaluation during the relevant nine-month

period. However, respondent refused to sign consent papers for the evaluation multiple times, until

she finally did so on January 25, 2024.

¶ 16 Regarding housing, respondent lived with her adult son for the majority of the

nine-month period, sleeping on his couch. Respondent was then asked to leave and stayed at hotels

or churches.

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Cite This Page — Counsel Stack

Bluebook (online)
2025 IL App (4th) 241212-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-ja-illappct-2025.