In re R.L.

2025 IL App (4th) 241211-U
CourtAppellate Court of Illinois
DecidedAugust 20, 2025
Docket4-24-1211
StatusUnpublished

This text of 2025 IL App (4th) 241211-U (In re R.L.) 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 R.L., 2025 IL App (4th) 241211-U (Ill. Ct. App. 2025).

Opinion

2025 IL App (4th) 241211-U

NOTICE NO. 4-24-1211 FILED This Order was filed under August 20, 2025 Supreme Court Rule 23 and is IN THE APPELLATE COURT Carla Bender not precedent except in the 4th District Appellate limited circumstances allowed OF ILLINOIS Court, IL under Rule 23(e)(1). FOURTH DISTRICT

In re R.L., a Minor ) Appeal from the ) Circuit Court of (The People of the State of Illinois, ) Sangamon County Petitioner-Appellee, ) No. 21JA139 v. ) Anezka L., ) Honorable Respondent-Appellant). ) Karen S. Tharp, ) Judge Presiding.

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

ORDER

¶1 Held: The appellate court affirmed the trial court’s termination of respondent’s parental rights because the trial court’s unfitness and best interest findings were not against the manifest weight of the evidence and the termination proceedings were not fundamentally unfair.

¶2 Respondent, Anezka L., is the mother of R.L. (born July 2020). In September

2024, the trial court found respondent was an unfit parent and termination of respondent’s

parental rights would be in the minor’s best interest.

¶3 Respondent appeals, arguing (1) the trial court’s unfitness and best interest

findings were against the manifest weight of the evidence and (2) the termination proceedings

were fundamentally unfair. We disagree and affirm.

¶4 I. BACKGROUND

¶5 A. Procedural History

¶6 In November 2021, the State filed a petition for adjudication of wardship, alleging R.L. was neglected in that respondent (1) “failed to make a proper care plan for [R.L],”

(2) “ha[d] substance abuse issues,” and (3) maintained a home with “unsanitary conditions.” See

705 ILCS 405/2-3(1)(a), (b) (West 2020). (We note that, prior to the filing of the petition,

respondent had participated in an intact case with the Illinois Department of Children and Family

Services (DCFS).)

¶7 Later that same month, the trial court conducted a shelter care hearing and placed

temporary custody and guardianship of R.L. with the guardianship administrator of DCFS.

¶8 In July 2022, respondent entered a written stipulation to the allegation that R.L.’s

environment was injurious to her welfare due to the unsanitary conditions of respondent’s home,

and the trial court adjudicated R.L. neglected on that basis.

¶9 In August 2022, the trial court conducted a dispositional hearing, at which it

entered a written order finding respondent “unfit, unable or unwilling” for reasons other than

financial circumstances alone to care for, protect, train, educate, supervise, or discipline R.L. The

court also (1) adjudicated R.L. a ward of the court, (2) placed guardianship and custody of R.L.

with the guardianship administrator of DCFS, and (3) admonished respondent that she “must

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

require [R.L.] to be in care, or risk termination of [her] parental rights.”

¶ 10 B. The Termination Hearing

¶ 11 In February 2024, the State filed a motion for termination of parental rights,

alleging that respondent was an unfit parent because she (1) failed to maintain a reasonable

degree of interest, concern, or responsibility as to R.L.’s welfare (750 ILCS 50/1(D)(b) (West

2024)); (2) failed to make reasonable efforts to correct the conditions that were the basis for the

removal of R.L. from her care within the nine-month period of July 2022 to April 2023 (id.

-2- § 1(D)(m)(i)); and (3) failed to make reasonable progress toward the return of R.L. to her care

within the nine-month periods of July 2022 to April 2023 and April 2023 to January 2024 (id.

§ 1(D)(m)(ii)).

¶ 12 1. The Fitness Portion of the Termination Proceedings

¶ 13 In September 2024, the trial court conducted the fitness portion of the termination

proceedings. At the State’s request, the court took judicial notice of all the orders previously

entered in the case, including the adjudicatory and dispositional orders.

¶ 14 a. Adriane Beck

¶ 15 Adriane Beck testified that from March 2022 to August 2023, she was employed

at the Center for Youth and Family Services (CYFS) and served as R.L.’s caseworker. Prior to

Beck’s involvement, R.L. had another caseworker as part of an intact case.

¶ 16 Beck testified that R.L. came into care for “multiple reasons.” She explained that

R.L. was “developmentally delayed” and the house she lived in with respondent was unsanitary.

Additionally, respondent (1) “tested positive for meth[amphetamine],” (2) “was aggressive with

the DCFS staff,” and (3) “had a history of *** assault with her mother with [R.L.] present.” Beck

also testified that respondent had a safety plan that she violated by bringing R.L. “somewhere

*** she was not supposed to go” and respondent “only had one prenatal visit with R.L.”

¶ 17 When Beck took over as caseworker in March 2022, the service plan that was in

place required the following services: “housing, employment, cooperation, parenting, substance

abuse, visitation, anger management, parenting classes, and a psychological [evaluation],” as

well as mental health services and random drug tests.

¶ 18 i. Psychological Evaluation and Mental Health Services

¶ 19 Beck testified that respondent acted “defensive” about having to attend mental

-3- health services. Beck believed the services were necessary because she saw numerous horizontal

scars on respondent’s arms. Beck also described two incidents in May 2022 during which

respondent exhibited unusual behavior. During one visit, respondent gave R.L. a haircut, but

when the haircut did not turn out well, respondent “became extremely upset and was screaming

and cursing and punching herself in the head.” Around the same time, during a family and team

meeting to discuss appropriate dress with respondent after she had accidentally exposed her

breast to a male case aide, she “became very angry and started screaming, cursing at [Beck and

her supervisor], and she was asked to leave at that point.”

¶ 20 Beck stated that respondent completed a psychological evaluation, which resulted

in the recommendation that she (1) see a psychiatrist for medication and medication management

and (2) see a counselor weekly. Beck testified that respondent generally attended counseling,

although she missed 5 out of 10 sessions due to her phone being off and oversleeping. By April

2023, the counselor reported to Beck that, despite missing half of her sessions, respondent was

communicating well, in that she was not getting angry or exploding, but she was not engaging.

Beck explained that “she still wasn’t diving into anything to do with her mental health that was

substantial.”

¶ 21 ii. Substance Abuse Treatment and Drug Tests

¶ 22 Beck testified that by May 2022, respondent was engaged in outpatient treatment

services at Gateway Foundation (Gateway) and she completed those services around September

2022. However, between March 2022 and August 2022, respondent did not attend any of the

drug tests requested by the agency. Overall, between March 2022 and August 2023, although the

agency requested four drug tests per month, respondent attended only four or five in total.

Respondent told Beck that her work schedule was getting in the way of her attending the drug

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Cite This Page — Counsel Stack

Bluebook (online)
2025 IL App (4th) 241211-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-rl-illappct-2025.