In re J.B.

2026 IL App (1st) 251111-U
CourtAppellate Court of Illinois
DecidedJanuary 16, 2026
Docket1-25-1111
StatusUnpublished

This text of 2026 IL App (1st) 251111-U (In re J.B.) 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.B., 2026 IL App (1st) 251111-U (Ill. Ct. App. 2026).

Opinion

2026 IL App (1st) 251111-U

FIFTH DIVISION January 16, 2026

No. 1-25-1111

NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1). ______________________________________________________________________________

IN THE APPELLATE COURT OF ILLINOIS FIRST DISTRICT ______________________________________________________________________________

In re J.B., a Minor, ) ) (The People of the State of Illinois, ) Appeal from the ) Circuit Court of Petitioner-Appellee, ) Cook County. ) v. ) No. 2023 JA 00168 ) K.S. and R.B., ) Honorable ) Patrick T. Murphy, Respondents ) Judge Presiding. ) (R.B., Respondent-Appellant)). )

JUSTICE MIKVA delivered the judgment of the court. Presiding Justice Mitchell and Justice Oden Johnson concurred in the judgment.

ORDER

¶1 Held: The circuit court’s order terminating the parental rights of the father in this case is affirmed. The record reflects no legal error, and neither the court’s finding of unfitness based on a lengthy period without visitation nor its finding that termination was in the minor’s best interest was against the manifest weight of the evidence.

¶2 The respondent-appellant in this case, R.B., appeals from the termination of his parental

rights to J.B., his two-year-old biological daughter. J.B.’s biological mother, K.S., whose parental No. 1-25-1111

rights were also terminated, is not a party to this appeal.

¶3 The trial court found R.B. unfit to parent J.B. based on his “[f]ailure to maintain a

reasonable degree of interest, concern or responsibility as to the child’s welfare” (750 ILCS

50/1(D)(b) (West 2024). R.B. argues on appeal that the court erred as a matter of law, believing it

was required to make this finding, regardless of the extenuating circumstances that had prevented

him from regularly visiting J.B. for most of her life. He insists that, when properly considered,

those circumstances preclude a finding of unfitness.

¶4 R.B. also challenges the trial court’s finding that a termination of parental rights was in

J.B.’s best interest, arguing that the court did not reference the statutory best interest factors, gave

insufficient weight to the effect of termination on J.B.’s ability to know her biological family, and

improperly referred to the personal circumstances of the judge’s own family.

¶5 Although the record reflects that R.B. made significant efforts at times to see his daughter

and to do some of the services suggested, and although we agree with the trial court’s concerns

about some of the lapses in the agency’s efforts, we also agree with the court that the State carried

its burden of proving both unfitness and that it was in J.B.’s best interests to terminate R.B.’s

rights.

¶6 I. BACKGROUND

¶7 A. Initial Proceedings

¶8 J.B. (initially identified in the record as J.S.) was born on February 25, 2023, and taken

into protective custody on March 2, 2023. The State alleged, in its petition to adjudge her a ward

of the State, that J.B. was neglected, pursuant to section 2-3(1) of the Juvenile Court Act (Act),

because her environment was injurious to her welfare (705 ILCS 405/2-3(1)(b) (West 2022)) and

because she had tested positive for a controlled substance at birth (id. § 2-3(1)(c)). The State further

2 No. 1-25-1111

alleged that J.B. was abused, pursuant to section 2-3(2)(ii) of the Act, because a person responsible

for her welfare had created a substantial risk of serious physical injury to her by other than

accidental means (id. § 2-3(2)(ii)). The State asserted that K.S. had five other children in DCFS

custody, that she was noncompliant with services, and that both she and J.B. had tested positive

for illegal substances at the time of J.B.’s birth. The trial court found probable cause existed to

support the requested findings and awarded temporary custody of J.B. to the Department of

Children and Family Services (DCFS), with the right to place her in foster care.

¶9 Following an adjudication hearing on June 20, 2023, the trial court found that J.B. was both

neglected based on an injurious environment (id. § 2-3(1)(b)) and abused based on a substantial

risk of serious injury (id. § 2-3(2)(ii)). The court noted in its order that no one had appeared at the

hearing on behalf of DCFS. It further noted that although R.B. had submitted to DNA testing

shortly after this case was initiated, DCFS had failed to have J.B. tested, despite repeated requests

to do so by both the court and the State’s Attorney. The court admonished the agency, stating:

“Over the past month DCFS workers have routinely appeared late for trials or as in the present

case, not at all. This is unacceptable. Further, the fact that DCFS has had over three months to test

the child but ha[s] thus far refused to do so is equally unacceptable.” It ordered the agency to

promptly have J.B. tested so that paternity could be established.

¶ 10 On September 22, 2023, the court found, based on DNA evidence, that R.B. was J.B.’s

biological father. Following a disposition hearing held that same day, it adjudged J.B. a ward of

the court and found, pursuant to section 2-27 of the Act (705 ILCS 405/2-27(1) (West 2022)), that

both parents were unable, for other than financial circumstances alone, to care for J.B. and that

reasonable efforts made to avoid that result had been unsuccessful. The court appointed the DCFS

Guardianship Administrator as J.B.’s guardian, with the right to place her.

3 No. 1-25-1111

¶ 11 Over one year later, on November 25, 2024, R.B.’s appointed counsel moved to withdraw.

Counsel represented that he had diligently undertaken to represent R.B. in this matter but had been

“unable to secure any contact with him for a lengthy period of time, over six months.” According

to the attorney, R.B. had “failed to be assessed for reunification services, failed to participate in

visits, and failed to appear in Court[,] making further fruitful representation impossible.” The court

granted the motion on January 22, 2025.

¶ 12 That same day, the State moved to permanently terminate the parental rights of both K.S.

and R.B., pursuant to section 1(D) of the Adoption Act (750 ILCS 50/1(D) (West 2024)) and

section 2-29 of the Juvenile Court Act (705 ILCS 405/2-29) (West 2024)). The State asserted that

K.S. and R.B. were unfit to parent J.B. because they had each “[f]ail[ed] to maintain a reasonable

degree of interest, concern or responsibility as to [J.B.’s] welfare” (id. § 1(D)(b)) and failed, within

two separate nine-month periods following the court’s findings of neglect and abuse (June 20,

2023, through March 20, 2024, and March 17, 2024, through December 17, 2024) to make

reasonable efforts to correct the conditions that were the basis for J.B.’s removal (id. § 1(D)(m)).

As to R.B., the State additionally asserted abandonment (id. § 1(D)(a)), desertion (id. § 1(D)(c)),

and an evidenced intent to forego parental rights (id. § 1(D)(n)) as grounds for a finding of

unfitness. It noted that J.B. had resided in her foster parent’s home since March 2023, the foster

parent wished to adopt her, and the State believed that was in J.B.’s best interest.

¶ 13 B.

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Cite This Page — Counsel Stack

Bluebook (online)
2026 IL App (1st) 251111-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-jb-illappct-2026.