In re L.P.

2020 IL App (4th) 190701-U
CourtAppellate Court of Illinois
DecidedFebruary 26, 2020
Docket4-19-0701
StatusUnpublished

This text of 2020 IL App (4th) 190701-U (In re L.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 L.P., 2020 IL App (4th) 190701-U (Ill. Ct. App. 2020).

Opinion

NOTICE This order was filed under Supreme 2020 IL App (4th) 190701-U FILED Court Rule 23 and may not be cited February 26, 2020 as precedent by any party except in NO. 4-19-0701 Carla Bender the limited circumstances allowed 4th District Appellate under Rule 23(e)(1). IN THE APPELLATE COURT Court, IL

OF ILLINOIS

FOURTH DISTRICT

In re L.P., a Minor ) Appeal from the ) Circuit Court of (The People of the State of Illinois, ) Champaign County Petitioner-Appellee, ) No. 18JA28 v. ) Kari P., ) Honorable Respondent-Appellant). ) John R. Kennedy, ) Judge Presiding.

JUSTICE DeARMOND delivered the judgment of the court. Justices Cavanagh and Holder White concurred in the judgment.

ORDER ¶1 Held: The appellate court affirmed, concluding the trial court did not err in finding respondent unfit.

¶2 In April 2018, the State filed a petition for adjudication of wardship with respect

to L.P., the minor child of respondent, Kari P. The trial court made the minor a ward of the court

and placed custody and guardianship with the Department of Children and Family Services

(DCFS). In May 2019, the State filed a petition to terminate respondent’s parental rights. The

court found respondent unfit and determined it was in the minor’s best interests to terminate

respondent’s parental rights. ¶3 On appeal, respondent argues only that the trial court erred in finding her unfit.

She does not challenge the trial court’s best-interests finding. Accordingly, we confine our

discussion of the case to the finding of unfitness. We affirm.

¶4 I. BACKGROUND

¶5 A. Proceedings on the Petition for Adjudication of Wardship

¶6 In April 2018, the State filed a petition for adjudication of wardship with respect

to L.P., born in March 2018, the minor child of respondent and an unknown father. The State

alleged L.P. was neglected pursuant to section 2-3(1)(b) of the Juvenile Court Act of 1987

(Juvenile Court Act) (705 ILCS 405/2-3(1)(b) (West 2016)) because she was in an injurious

environment, as evidenced by (1) respondent’s failure to correct the conditions that resulted in a

prior adjudication of parental unfitness regarding L.P.’s sibling and (2) the fact that the alleged

injurious environment would expose L.P. to respondent’s substance abuse. The State’s petition

indicated respondent was incarcerated at Logan Correctional Center.

¶7 From April 3, 2018, to April 5, 2018, the trial court conducted a shelter-care

hearing. The trial court found probable cause to believe L.P. was neglected—because of

respondent’s (1) incarceration, (2) “long history” of substance abuse, and (3) prior adjudication

of unfitness with respect to L.P.’s sibling—and placed temporary custody and guardianship with

DCFS.

¶8 In June 2018, following an adjudicatory hearing, the court entered an order

finding L.P. neglected. See In re L.P., 2019 IL App (4th) 180666-U, ¶¶ 8-26 (discussing the

evidence presented at the adjudicatory hearing and the trial court’s ruling). In September 2018,

following a dispositional hearing, the court adjudicated L.P. neglected, made her a ward of the

court, and placed custody and guardianship with DCFS. See id. ¶¶ 27-34 (discussing the

-2- evidence presented at the dispositional hearing and the trial court’s ruling). We affirmed the trial

court’s judgments. Id. ¶ 1.

¶9 B. Proceedings on the Motion to Terminate Parental Rights

¶ 10 In May 2019, the State filed a motion to terminate respondent’s parental rights,

alleging respondent was unfit because she failed to (1) make reasonable progress toward the

minor’s return during the nine-month period from August 14, 2018, to May 14, 2019 (750 ILCS

50/1(D)(m)(ii) (West 2018)), and (2) maintain a reasonable degree of interest, concern, or

responsibility as to the minor’s welfare (750 ILCS 50/1(D)(b) (West 2018)).

¶ 11 On July 19, 2019, and August 9, 2019, the trial court conducted the fitness

hearing. Erica Stobaugh worked for Children’s Home and Aid as a “Healthy Families home

visitor.” Stobaugh was the case worker assigned to respondent’s case from July 2018 to May

2019, and she indicated respondent was incarcerated throughout the duration of her time on the

case. Stobaugh testified respondent’s service plan required her to complete substance abuse

treatment and parenting classes. When Stobaugh last spoke to respondent, in May 2019,

respondent “was on a waiting list for the substance abuse [program], but she was participating in

[the prison’s] Women of Dignity program, which was four classes, which one of them did

include parenting ***.”

¶ 12 Meredith Brumfield worked as a case manager for One Hope United. Brumfield

was assigned to respondent’s case on May 15, 2019, and she indicated respondent had been

incarcerated for the entirety of the case. Brumfield testified respondent’s service plan required

her “to be in a parenting class” and “a substance abuse program.” When Brumfield was assigned

to respondent’s case, respondent had completed no substance abuse or parenting classes.

-3- ¶ 13 Respondent, at the time of the hearing, had been incarcerated for 22 months due

to a possession-of-a-stolen-vehicle conviction. Originally, her projected release date was in June

2020. However, due to enrollment in one of the prison’s educational programs, respondent

believed her release date “should be the end of February, beginning of March [2020].”

Respondent testified she had participated in several programs offered at the prison. In February

2019, she completed “Life Smart for Women,” which “goes over like being healthy, going over

health issues for women”; in March 2019, respondent successfully completed “Start Now,” a

“reentry program” that “revolve[d] around talking about women’s issues, your drug abuse,

trauma, PTSD”; she was also enrolled in a “Construction Occupations class” until July 2019,

when she had to drop the class in order to participate in the prison’s drug treatment program

because it “was more important.” Respondent testified she had been on the drug treatment

program’s waiting list since she began serving her sentence.

¶ 14 Following presentation of the evidence and recommendations of counsel, the trial

court found the State proved respondent unfit for failing to make reasonable progress toward the

minor’s return during the nine-month period from August 14, 2018 to May 14, 2019. (The court

did find respondent had maintained a reasonable degree of interest, concern, or responsibility as

to the minor’s welfare.) With respect to its finding of unfitness, the trial court reasoned

respondent had made no progress toward completion of substance abuse treatment or parenting

classes during the relevant time period, as was required by her service plan. Although respondent

had been on the waiting list for substance abuse treatment, she did not secure enrollment in the

program until after the nine-month period had concluded. As for the parenting classes, the court

acknowledged there was evidence respondent had completed a course “that had a session

involving parenting education,” but ultimately found there was “not evidence of completion of

-4- parenting education, certainly not in any form that would show requisite acquisition of skills to

be able to parent this young child.”

¶ 15 This appeal followed.

¶ 16 II. ANALYSIS

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Cite This Page — Counsel Stack

Bluebook (online)
2020 IL App (4th) 190701-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-lp-illappct-2020.