In re M.H.

2025 IL App (4th) 241472-U
CourtAppellate Court of Illinois
DecidedMarch 25, 2025
Docket4-24-1472
StatusUnpublished
Cited by1 cases

This text of 2025 IL App (4th) 241472-U (In re M.H.) 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 M.H., 2025 IL App (4th) 241472-U (Ill. Ct. App. 2025).

Opinion

NOTICE 2025 IL App (4th) 241472-U FILED This Order was filed under March 25, 2025 Supreme Court Rule 23 and is NO. 4-24-1472 Carla Bender not precedent except in the limited circumstances allowed 4th District Appellate under Rule 23(e)(1). Court, IL IN THE APPELLATE COURT

OF ILLINOIS

FOURTH DISTRICT

In re M.H., a Minor ) Appeal from the ) Circuit Court of (The People of the State of Illinois, ) Tazewell County Petitioner-Appellee, ) No. 23JA203 v. ) Samantha R., ) Honorable Respondent-Appellant). ) Timothy J. Cusack, ) Judge Presiding.

JUSTICE VANCIL delivered the judgment of the court. Justices Zenoff and Lannerd concurred in the judgment.

ORDER

¶1 Held: The appellate court affirmed, finding the trial court’s determination that respondent was unfit at the dispositional hearing was not against the manifest weight of the evidence.

¶2 Respondent, Samantha R., appeals the trial court’s dispositional order finding her

unfit as to her minor child, M.H. (born 2015). On appeal, she argues the court’s dispositional

unfitness finding was against the manifest weight of the evidence, and, rather than being found

unfit, she should instead have been found unable.

¶3 We affirm.

¶4 I. BACKGROUND

¶5 On November 8, 2023, the Illinois Department of Children and Family Services

(DCFS) filed a petition for adjudication of wardship of M.H., alleging he was neglected pursuant

to section 2-3(1)(b) of the Juvenile Court Act of 1987 (Act) (705 ILCS 405/2-3(1)(b) (West 2022)) in that his environment was injurious to his welfare. The petition alleged that on or about

June 29, 2023, DCFS received a hotline call regarding injuries observed on M.H., including a

bruise on the side of his face, a bite mark on his right shoulder, and a mark on his lower back.

The same day, a DCFS investigator spoke to M.H. at the home of his father, Ryan H. M.H. told

the investigator that when he was not living with his father, he lived with respondent, her

boyfriend, Joel C., and his four siblings. M.H. stated that a few days before, he attempted to run

away from respondent’s home after respondent became angry with him when she believed he

gave her the middle finger. He stated that respondent grabbed him, slapped his face multiple

times, and forced his right arm into his mouth, making it hard for him to breathe. This incident

was observed by multiple siblings. A recording of the incident taken by one of the children

showed respondent’s arm around M.H.’s neck while M.H.’s feet appeared to be off the ground.

M.H. stated that respondent and Joel often became upset with the children and would yell, curse,

spank them, “pop them in the mouth,” and slap them. M.H. stated that he felt safe living with his

father but not respondent. Interviews with M.H.’s siblings and other family members confirmed

that respondent and Joel were frequently physical with both the children and each other and that

there was ongoing drug use in the home.

¶6 The petition further alleged that on or about September 5, 2023, DCFS was

notified that Ryan H. had died suddenly as the result of a drug overdose. M.H. was present at the

time his deceased father was found. M.H. began living with his paternal grandmother, Susan H.

¶7 The petition concluded that, based on the allegations of violence concerning

respondent, it was in the best interest of M.H. and the public that he be adjudicated a ward of the

court.

¶8 On January 24, 2024, the trial court entered an order of no contact against

-2- respondent as to M.H. The order granted supervised parenting time between respondent and

M.H. at the discretion of DCFS but otherwise prohibited communication between the two.

¶9 On October 16, 2024, the trial court held an adjudicatory hearing on the petition.

The State moved to enter the narrative portion of the petition and informed the court it had

witnesses who would testify consistently with the information therein. No other party presented

evidence or argument. Based on the State’s petition and proffer, the court found the State had

proven by clear and convincing evidence that M.H. was neglected.

¶ 10 The trial court then moved immediately to a dispositional hearing. It considered a

report prepared by a caseworker on M.H.’s case. The report stated that respondent had either

completed or was in the process of completing all of her recommended services, including

parenting classes, a substance abuse assessment, anger management classes, and counseling. No

further instances of physical abuse had been reported.

¶ 11 The report also stated that Susan H. had been cooperative with DCFS and had not

been recommended for any services. The report found her home was appropriate, M.H.’s needs

were being met, and M.H. felt safe residing with her. It found no concerns with M.H. remaining

in her care.

¶ 12 According to the report, M.H. expressed that he enjoyed visits with his brother,

A.H., but did not wish to continue visits with respondent. On April 15, 2024, visits between

M.H. and respondent were suspended following a meeting between DCFS staff, M.H.’s doctors,

and all attorneys involved in the case. On August 8, 2024, M.H.’s therapist recommended that

visits with respondent remain suspended due to M.H.’s “current mental status which includes

anxiety, anger, and distrust of” his mother. She confirmed on September 24, 2024, that he

remained “very angry” with respondent.

-3- ¶ 13 At the dispositional hearing, the caseworker confirmed on questioning from

respondent’s counsel that respondent had completed or was in the process of completing all

services recommended up to that point and, to her belief, met minimal parenting standards.

Counsel asked if M.H. appeared to be happy at the visits he had with respondent. The

caseworker confirmed that he did. On later questioning from the guardian ad litem, however, the

caseworker acknowledged that M.H. told her he acted happy at visits with respondent in order to

continue seeing his brother, A.H., but did not actually wish to have visits with his mother.

¶ 14 Counsel for Ben G., A.H.’s biological father, asked the caseworker if respondent

had completed any domestic violence services. The caseworker confirmed she had not. Counsel

then asked if those services should have been recommended based on the allegations of physical

violence made against respondent. The caseworker confirmed that they should have but

explained that service recommendations for each case were generated by a computer program

and the program did not recommend domestic violence services for respondent.

¶ 15 At the conclusion of questioning, the trial court asked for recommendations. The

State recommended that M.H. remain placed with Susan and that respondent be found unable to

care for him. The State further recommended that, based on Susan’s fitness, M.H.’s case be

closed. Counsel for respondent recommended that respondent be found fit but unable and asked

that the case remain open, with a goal of returning M.H. home to respondent.

¶ 16 The trial court found respondent unfit as to M.H. and ordered that custody of the

minor remain with Susan, whom it found to be fit. The court additionally ordered respondent to

cooperate with DCFS, engage in counseling, complete a drug assessment and follow its

recommendations, and complete domestic violence services. A dispositional order entered the

same day made M.H.

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Related

In re M.H.
2025 IL App (4th) 250271-U (Appellate Court of Illinois, 2025)

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Bluebook (online)
2025 IL App (4th) 241472-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-mh-illappct-2025.