In re M.K.

2021 IL App (4th) 210049-U
CourtAppellate Court of Illinois
DecidedJune 11, 2021
Docket4-21-0049
StatusUnpublished

This text of 2021 IL App (4th) 210049-U (In re M.K.) 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.K., 2021 IL App (4th) 210049-U (Ill. Ct. App. 2021).

Opinion

NOTICE 2021 IL App (4th) 210049-U FILED This Order was filed under NO. 4-21-0049 June 11, 2021 Supreme Court Rule 23 and is Carla Bender not precedent except in the 4th District Appellate limited circumstances allowed IN THE APPELLATE COURT Court, IL under Rule 23(e)(1). OF ILLINOIS

FOURTH DISTRICT

In re M.K., a Minor ) Appeal from the ) Circuit Court of (The People of the State of Illinois, ) Livingston County Petitioner-Appellant, ) No. 19JA71 v. ) Mark Z., ) Honorable Respondent-Appellee). ) Jennifer H. Bauknecht, ) Judge Presiding.

JUSTICE STEIGMANN delivered the judgment of the court. Justices DeArmond and Cavanagh concurred in the judgment.

ORDER

¶ 1 Held: The appellate court affirmed the judgment of the trial court that denied the State’s expedited petition to terminate respondent’s parental rights because the trial court’s findings were not against the manifest weight of the evidence.

¶2 Respondent, Mark Z., is the father of M.K. (born March 2010). In December

2019, the State filed an amended petition for adjudication of wardship seeking to terminate

respondent’s parental rights in an expedited manner. See 705 ILCS 405/1-2 (West 2018). In

November 2020, the trial court found M.K. was a neglected minor and respondent was an unfit

parent pursuant to section 1(D) of the Adoption Act. 750 ILCS 50/1(D)(g) (West 2018).

¶3 In December 2020, the court conducted a dispositional hearing and adjudicated

M.K. a ward of the court. However, the court denied the State’s request to terminate

respondent’s parental rights because it found (1) the Department of Children and Family

Services (DCFS) did not make reasonable efforts at reunification, (2) the State had not shown an aggravating circumstance, and (3) termination was not in M.K.’s best interest.

¶4 The State appeals, arguing that the trial court’s findings regarding (1) reasonable

efforts and (2) aggravating circumstances were against the manifest weight of the evidence. We

conclude that the trial court properly declined to terminate respondent’s parental rights because

the court found that termination was not in M.K.’s best interest.

¶5 I. BACKGROUND

¶6 A. Procedural History

¶ 7 In November 2019, the State filed a petition for adjudication of wardship, alleging in relevant

part that M.K. was a neglected minor, as defined by the Juvenile Court Act of 1987 (Act) (705

ILCS 405/2-3(2)(i) (West 2018)), in that respondent “inflicts, causes to be inflicted, or allows to

be inflicted upon such minor physical injury, by other than accidental means, which causes ***

impairment of physical health[.]” The State further alleged that respondent created a substantial

risk of physical injury and an environment injurious to M.K.’s welfare due to domestic violence.

On the same day that the petition was filed, the trial court conducted a shelter care hearing and

placed temporary custody and guardianship with the guardianship administrator of DCFS.

¶8 In December 2019, the State filed an amended petition requesting the court

terminate respondent’s parental rights because he was an unfit parent in that he “failed to protect

the minor from conditions within her environment injurious to the minor’s welfare, pursuant to

750 ILCS 50/1(D)(g) [(West 2018)].” The State further alleged it was in M.K.’s best interest to

have respondent’s parental right terminated and sought that determination on an expedited basis.

¶9 B. The Joint Adjudicatory and Parental Termination Hearing

¶ 10 In June 2020, the trial court conducted an adjudicatory hearing at which it also

considered whether respondent’s parental rights should be terminated because he was an unfit

-2- parent as alleged in the amended petition. We note that a report of proceedings for the hearing

does not appear in the record. The docket entry for that date indicates that the State presented the

testimony of two witnesses and the court admitted into evidence (1) a DVD of an interview with

respondent and (2) pictures of M.K. depicting bruising on her face.

¶ 11 In July 2020, the trial court conducted a continued adjudicatory hearing at which

respondent moved for a directed finding on the issue of unfitness. The court continued the matter

and allowed the parties to submit written arguments. In his brief in support of his motion for

directed finding, respondent argued that the State had failed to demonstrate that aggravating

factors existed to justify the expedited termination of parental rights and “there was no showing

that reasonable efforts are inappropriate and unsuccessful.”

¶ 12 The State responded that section 2-21(5) of the Act (705 ILCS 405/2-21(5) (West

2018)) controlled and set forth the procedure for expedited termination proceedings. At the

adjudicatory stage, the State was required to prove (1) by a preponderance of the evidence that

the child is abused or neglected and (2) by clear and convincing evidence that the parent is an

unfit person. The State maintained that whether an aggravating factor existed and reasonable

efforts had been made were issues to be proved at the dispositional or best interest stage of the

expedited proceedings. The State explained, “Because this case is currently in the adjudicatory

phase of the proceedings the State will make no further argument regarding reasonable efforts or

aggravating circumstances and will merely assert that the State has every intention of providing

such evidence at the appropriate stage of the proceedings: the dispositional/best interest hearing.”

¶ 13 In November 2020, the trial court concluded the adjudicatory hearing and entered

a written order finding that the State had proved by a preponderance of the evidence that M.K.

was abused and neglected. The docket entry stated as follows: “Court finds that State has met the

-3- burden of proof by preponderance of evidence and finds minor abused and that there is clear and

convincing evidence that State has met the burden of proof on counts with mother and father.”

The court continued the case for a best-interest and dispositional hearing.

¶ 14 C. The Dispositional Hearing

¶ 15 In December 2020, the trial court conducted a dispositional hearing and

considered whether it was in M.K.’s best interest to terminate respondent’s parental rights.

¶ 16 1. The State’s Evidence

¶ 17 Taylor McDonald testified that she was the caseworker on the case since it was

opened in November 2019. McDonald testified that M.K. was involved in a prior termination

case when she was three years old, seven years before the instant hearing. That case was opened

because M.K.’s mother had substance abuse problems. Respondent stated to McDonald that, in

that prior case, he completed domestic violence, anger management, and parenting services. The

outcome of the case was that M.K. was returned home to respondent.

¶ 18 McDonald testified that throughout the entire life of the case, M.K. had been with

her maternal grandmother, who wished to adopt M.K. McDonald stated that M.K.’s grandmother

(1) provided for all of her material needs, (2) was with her every day, and (3) helped her go to

school, doctor’s appointments, and counseling. McDonald stated M.K. had a strong bond and

relationship with her grandmother, and M.K.

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Bluebook (online)
2021 IL App (4th) 210049-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-mk-illappct-2021.