In re J.H.S.

2025 IL App (2d) 250056-U
CourtAppellate Court of Illinois
DecidedNovember 4, 2025
Docket2-25-0056
StatusUnpublished

This text of 2025 IL App (2d) 250056-U (In re J.H.S.) 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.H.S., 2025 IL App (2d) 250056-U (Ill. Ct. App. 2025).

Opinion

2025 IL App (2d) 250056-U No. 2-25-0056 Order filed November 4, 2025

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

IN THE

APPELLATE COURT OF ILLINOIS

SECOND DISTRICT ______________________________________________________________________________

In re J.H.S., a Minor ) Appeal from the Circuit Court ) of Kane County. ) ) ) ) No. 20-JA-137 ) ) Honorable (People of the State of Illinois, Petitioner- ) Kathryn D. Karayannis, Appellee v. Tarah H., Respondent-Appellant). ) Judge, Presiding. ______________________________________________________________________________

JUSTICE McLAREN delivered the judgment of the court. Justices Hutchinson and Jorgensen concurred in the judgment.

ORDER

¶1 Held: (1) Issue of findings made in a temporary custody hearing was moot, as there was a subsequent adjudication of wardship supported by adequate evidence; (2) plenary order of protection was a final and appealable order and should have been appealed within 30 days of its issuance; (3) it is the duty of a guardian ad litem, not the parent, to call the rights of the minor to the attention of the court; (4) failure to adequately contest all grounds upon which a finding of unfitness was based renders the issue of unfitness moot; and (5) appellate court cannot find best interests determination to be against the manifest weight of the evidence where appellant fails to properly and adequately brief the issue. 2025 IL App (2d) 250056-U

¶2 Respondent, Tarah H. appeals from the trial court’s orders finding her to be an unfit parent

and that it was in the best interests of her son, J.H.S., that her parental rights be terminated. We

affirm.

¶3 I. BACKGROUND

¶4 In August 2020, the State filed a petition alleging that J.H.S. was a neglected minor in that:

(1) J.H.S. was “born with cocaine in his urine, blood or m[e]conium which is not result of medical

treatment administered to the mother or the infant” (705 ILCS 405/2-3(1)(C) (2) (West 2018)); (2)

his environment was injurious to his welfare in that defendant’s substance abuse issues and/or

history placed the minor at risk of harm, and his father, Robert Scholl, 1 failed to protect and/or

care for him (705 ILCS 405/2-3(1)(b) (West 2018)); and (3) his environment was injurious to his

welfare in that Scholl’s domestic violence issues and/or history placed him at risk of harm, and

defendant failed to protect and/or care for him (705 ILCS 405/2-3(1)(b) (West 2018)). At an

August 27, 2020, shelter care hearing, the trial court found that probable cause for the filing of the

petition existed based on Tarah’s knowing and voluntary stipulation that State’s witnesses would

testify that J.H.S.’s urine tested positive for cocaine and that his umbilical cord tested positive for

benzodiazepine. Tarah had tested positive for cocaine on July 1, 2020, and she and Robert had

lived together throughout pregnancy. Further, Tarah’s parental rights to J.H.S.’s sibling were

terminated in April 2019, after Robert attempted to push Tarah out of a vehicle on I-90 while the

sibling was in the back seat.

¶5 The court found immediate and urgent necessity to remove J.H.S. from the home and that

reasonable efforts could not prevent or eliminate the necessity for removal; therefore, the court

granted temporary custody of J.H.S. to the Illinois Department of Children and Family Services

1 Robert has filed a separate appeal in case no. 2-25-0026.

-2- 2025 IL App (2d) 250056-U

(DCFS), which was authorized to place J.H.S. Tarah and Robert were admonished that they must

cooperate with DCFS, comply with the terms of the service plan, and correct the conditions that

required J.H.S. to be in care or risk termination of their parental rights. CASA Kane County was

appointed Guardian ad litem (GAL) for J.H.S., and attorneys were appointed for the GAL.

¶6 Following a hearing on the State’s petition, the court, on November 6, 2020, found J.H.S.

abused or neglected as defined by 705 ILCS 405/2-3 in that, as a newborn, he was exposed to illicit

drugs. The finding was based again on Tarah and Robert’s “knowing and voluntary stipulation”

that the State’s evidence would include that J.H.S. tested positive for a controlled substance,

cocaine, and his umbilical cord tested positive for a benzodiazepine, not as the result of any

medical treatment. Tarah tested positive for cocaine on or about July 1, 2020, and Tarah and

Robert lived together throughout the pregnancy. The terms and conditions concerning the

temporary custody of J.H.S. remained in place, and Tarah and Robert were again admonished that

they risked termination of their parental rights if they did not cooperate with DCFS, comply with

the terms of the service plan, and correct the conditions that required J.H.S. to be in care.

¶7 On December 4, 2020, the trial court entered a dispositional order finding that it was

“consistent with the health, welfare and safety of the minor and in the best interest of the minor to

make the minor a ward of the Court.” Tarah was found unfit, for reasons other than financial

circumstances alone, “to care for, protect, train, educate, supervise or discipline the minor and

placement with her is contrary to the health, safety and best interests of the minor” because Tarah

had stipulated “that services have been identified for her to complete.” Those services included

domestic violence victim services, substance abuse evaluation, compliance with

recommendations, maintaining sobriety, submitting to random drops, individual therapy,

psychiatric treatment and medication compliance, couples counseling, parenting classes and

-3- 2025 IL App (2d) 250056-U

coaching. Reasonable efforts and appropriate services aimed at reunifying the family could not

prevent or eliminate the necessity for removal of J.H.S. from the home. Guardianship and custody

of J.H.S. was with DCFS with the right to place him. The court set a permanency goal of return

home within 12 months. Tarah was again admonished that she must cooperate with DCFS, comply

with the terms of the service plan, and correct the conditions that required J.H.S.to be in care or

she would risk termination of her parental rights.

¶8 On December 21, 2022, the State filed petitions to terminate the parental rights of both

Tarah and Robert. The State alleged that Tarah was an unfit person to have a child in that she: (1)

failed to maintain reasonable degree of interest, concern or responsibility as to J.H.S.’s welfare

under 750 ILCS 50/1 (D)(b); (2) failed to protect J.H.S. from conditions within his environment

that were injurious to his welfare under 750 ILCS 50/1(D)(g); (3) failed to make reasonable efforts

to correct the conditions that were the basis for the removal of J.H.S. from Tarah during the nine-

month period between January 19, 2022, and October 19, 2022, after an adjudication of neglect

under 750 ILCS 50/1

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Bluebook (online)
2025 IL App (2d) 250056-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-jhs-illappct-2025.