In re T.R.

• Court: Appellate Court of Illinois
• Decided: June 8, 2026
• Docket: 4-26-0045
• Status: Unpublished

Opinion

2026 IL App (4th) 260045-U

NOS. 4-26-0045, 4-26-0047, 4-26-0049, 4-26-0051, 4-26-0053 cons. NOTICE This Order was filed under IN THE APPELLATE COURT FILED Supreme Court Rule 23 and is June 8, 2026 not precedent except in the OF ILLINOIS Carla Bender limited circumstances allowed 4th District Appellate under Rule 23(e)(1). Court, IL FOURTH DISTRICT

In re T.R., Shy. R., Sham. R., J.R., and Shan. R., Minors ) Appeal from the ) Circuit Court of (The People of the State of Illinois, ) Rock Island County Petitioner-Appellee, ) Nos. 25JA67 v. ) 25JA68 Tiffany R., ) 25JA69 Respondent-Appellant). ) 25JA70 ) 25JA71 ) ) Honorable ) Norma Kauzlarich, ) Judge Presiding

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

ORDER

¶1 Held: The appellate court affirmed, finding (1) the trial court’s neglect findings were not against the manifest weight of the evidence and (2) its dispositional orders were not an abuse of discretion.

¶2 In August 2025, the State filed petitions for adjudication of wardship regarding

T.R. (born February 2008), Shy. R. (born January 2014), Sham. R. (born May 2015), J.R. (born

May 2017), and Shan. R. (born November 2021), the minor children of respondent mother,

Tiffany R. The trial court granted the petitions, adjudicating T.R. abused and neglected and the

remaining children neglected and making them wards of the court. Tiffany appealed.

¶3 I. BACKGROUND

¶4 On August 6, 2025, the State filed petitions for adjudication of wardship, asserting T.R., Shy. R., Sham. R., J.R., and Shan. R., should be made wards of the court. The

petitions alleged T.R. was neglected and abused pursuant to sections 2-3(1)(b) and 2-3(2)(i) of

the Juvenile Court Act of 1987 (Act) (705 ILCS 405/2-3(1)(b), (2)(i) (West 2024)), and Shy. R.,

Sham. R., J.R., and Shan. R. were neglected pursuant to section 2-3(1)(b) of the Act (705 ILCS

405/2-3(1)(b) (West 2024)).

¶5 The petitions alleged the Illinois Department of Children and Family Services

(DCFS) received a report alleging Tiffany “battered [T.R.] and left her stranded on the highway

without a phone or means of communication.” A DCFS investigator interviewed T.R. at the

hospital where she was receiving treatment for her injuries. T.R. reported Tiffany became angry

when she observed T.R. closing the car door on her sibling. Tiffany “verbally assaulted [T.R.]

and then started striking her mouth and head repeatedly.” T.R.’s four younger siblings, Shy. R.,

Sham. R., J.R., and Shan. R., were in the vehicle, along with M.G., their foster sibling. Tiffany

continued to batter T.R. while driving. During the incident, Tiffany was having a phone

conversation with T.R.’s father, Morrio R., who “heard what was occurring but did not say

anything.” Tiffany ultimately stopped the vehicle, took T.R.’s shoes and phone, and told T.R. to

“ ‘get the fuck out of the car.’ ” Tiffany drove away, leaving T.R. on the side of the interstate.

¶6 T.R.’s face, arms, and hands were bloodied, her eyes were bloodshot, and her

eyes and face were swollen. Eventually, another driver stopped, picked up T.R., and took her to

the hospital. Tiffany was subsequently arrested and charged with domestic battery in Rock Island

case No. 25-DV-157.

¶7 DCFS took protective custody of T.R. and placed her in relative foster care on

August 5, 2026. Morrio agreed to care for the other children and ensure Tiffany “was not living

in the family home or having unsupervised contact with the children.” Morrio indicated he would

-2- obtain an emergency order of protection against Tiffany, but the order was denied when Morrio

and Tiffany “appeared in court together and indicated that they were seeking the order because

DCFS made them do so.” When another DCFS investigator visited the family home to discuss

moving the other children to relative foster care, Morrio began yelling at T.R., blaming her for

their predicament.

¶8 After a hearing, the trial court granted the children’s temporary custody to DCFS.

¶9 On August 15, 2025, a protective order, signed by Morrio, was submitted to the

trial court. The court approved and signed the order, confirming with both parents that Tiffany

“would stay away from these kids and from [Morrio] as long as [Morrio] has them.” The court

vacated the temporary custody orders for Shy. R., Sham. R., J.R., and Shan. R., and permitted

them to return to Morrio’s care. T.R.’s temporary custody remained with DCFS.

¶ 10 At the adjudicatory hearing, Sergeant Joseph Miletich of the Silvis Police

Department testified he spoke to Tiffany after the events in question occurred. According to

Tiffany, T.R. “had tried to fight her.” Tiffany asserted she observed T.R. “slamming the car door

on one of the younger siblings.” Tiffany and T.R. got into a verbal argument, which escalated

into physical violence. Tiffany told Miletich that T.R. “was trying to jump out of the vehicle” as

she was driving. When Miletich asked how T.R. exited the vehicle, Tiffany answered, “ ‘I put

her out.’ ” When asked why she did not report the altercation to law enforcement, Tiffany said

“she didn’t want to get [T.R.] into trouble.” When Miletich interviewed Tiffany, she was

unaware of T.R.’s whereabouts. After Miletich informed her that T.R. was in the hospital,

Tiffany did not ask how T.R. got there, nor did she indicate she attempted to look for T.R.

Miletich did not observe any injuries on Tiffany’s body.

-3- ¶ 11 Miletich conducted a phone interview with T.R., who said the altercation began

when she closed the car door on her younger sibling, which upset Tiffany. Tiffany told T.R. that

she was “going to beat her ass,” and she “struck [T.R.] in the face.” T.R. hit back, and she

“crawl[ed] onto the floor of the passenger side as [Tiffany] continued to hit her.” Tiffany “kicked

[T.R.] out of the car” at a “no U-turn area” on the highway, and a passerby picked her up and

took her to the hospital.

¶ 12 Kristin Bruns, a DCFS child protection specialist, testified DCFS received a

hotline call on August 3, 2025, alleging T.R. was in the hospital after “being battered by her

mother” and suffering “bone fractures and head injuries.” Bruns attended an interview with T.R.,

during which she observed T.R.’s nose was swollen and her eyes “were completely bloodshot to

the point there was [sic] no whites in either eye.” T.R. “appeared very sad and defeated.” T.R.’s

recounting of the events in question largely mirrored her statements to Miletich. On the same

day, Bruns interviewed J.R., Shy. R., and Sham. R., all of whom corroborated T.R.’s statements.

Bruns’s efforts to interview Shan. R. and M.G. were unsuccessful.

¶ 13 When Bruns spoke with Tiffany, Tiffany stated, “[T.R.] was trying to fight her.”

Morrio asserted he was at work when Tiffany called him, saying, “ ‘[T]his girl is trying to fight

me.’ ” Morrio insisted he had “nothing to do with the situation.” Morrio believed the altercation

“was a mutual fight” between Tiffany and T.R.

¶ 14 T.R. subsequently indicated she no longer felt safe in Morrio’s home, and Bruns

spoke with Morrio and T.R. Morrio expressed confusion, insisting he had “never done anything

to [T.R.] to make her feel unsafe.” Bruns testified that during the conversation, Morrio became

upset with T.R. and yelled at her, blaming T.R. for the family’s predicament. T.R. responded by

telling Morrio to look at her face and reminding him that her injuries were not self-inflicted.

-4- ¶ 15 The trial court found, “[T]he State has met its burden of proof, that it is in the best

interest of the children that they be made wards of the Court.” However, the court determined all

the children except T.R. would stay with Morrio pursuant to the protective order, and the court

appointed DCFS as T.R.’s guardian. The court reiterated, “Everything is going to remain the

same for now. Until the dispositional hearing, everything stays the same.” The court entered a

written order finding T.R. was abused and neglected and the younger children were neglected.

¶ 16 On December 9, 2025, Lutheran Social Services of Illinois (LSSI) filed a

dispositional hearing report, which recommended the children be retained as wards of the court.

The report recommended T.R. remain in traditional foster care and the younger children remain

with Morrio. The report recommended T.R.’s permanency goal be changed to independence, as

she was going to turn 18 in a few months and she “expressed that she does not have a desire to

return home or be in communication with her parents at this time.”

¶ 17 LSSI also filed an integrated assessment, which recommended Tiffany, inter alia,

complete anger management and parenting classes, engage in individual and family

psychotherapy, maintain stable income and housing, and sign consents for treatment records. The

agency remained concerned about Tiffany’s “parenting practices, impulse control, and capacity

to maintain appropriate boundaries during periods of heightened stress.” Tiffany exhibited

“limited expression of remorse and insight into the seriousness of the incident,” which suggested

a lack of accountability or emotional awareness.

¶ 18 On January 8, 2026, LSSI filed a status alert, notifying the trial court that Tiffany

had completed domestic violence services, an anger management program, and parenting classes.

Tiffany had not yet begun her recommended psychotherapy.

-5- ¶ 19 At the dispositional hearing on January 29, 2026, the trial court took judicial

notice of the dispositional hearing report, integrated assessment, and status alert. The State rested

on the report. Tiffany told the court she was “going to be working with the agency” to complete

the recommended psychotherapy. Tiffany agreed with the report’s recommendation that T.R.’s

permanency goal should be independence. The court approved the integrated assessment’s

recommendations pertaining to Tiffany. The court determined T.R. would remain a ward of the

court and her goal would be independence. The court found the younger children would remain

wards of the court and stay in Morrio’s care.

¶ 20 The trial court entered a dispositional order finding Tiffany was unable to care

for, protect, train, or discipline the minors because she needed to complete the recommended

services. The order found the service plan and its recommendations appropriate, and it sent a

permanency goal of independence for T.R. and reunification for the younger children.

¶ 21 This appeal followed.

¶ 22 II. ANALYSIS

¶ 23 On appeal, Tiffany argues (1) the trial court’s neglect findings regarding Shy. R.,

Sham. R., J.R., and Shan. R. were against the manifest weight of the evidence and (2) its orders

making the younger children wards of the court were not supported by an adequate factual basis.

Tiffany does not challenge the court’s judgments regarding T.R. We affirm.

¶ 24 A. Standard of Review

¶ 25 The Act provides the two-step process trial courts follow when determining

whether to make a minor a ward of the court. See In re A.P., 2012 IL 113875, ¶ 18; 705 ILCS

405/2-18, 2-22 (West 2024). During the first step, the court conducts an adjudicatory hearing to

identify whether the minor is abused, neglected, or dependent. See 705 ILCS 405/2-18(1) (West

-6- 2024). If so, the court must then conduct a dispositional hearing to decide whether it is in the best

interest of the minor to be made a ward of the court. See 705 ILCS 405/2-22(1) (West 2024).

When making its determination, the court will consider “whether the parents *** are unfit or are

unable, for some reason other than financial circumstances alone, to care for, protect, train or

discipline the minor or are unwilling to do so,” as well as whether “the health, safety, and best

interest of the minor will be jeopardized if the minor remains in the custody of the minor’s

parents.” 705 ILCS 405/2-27(1) (West 2024).

¶ 26 “The paramount consideration in proceedings under the Act is the best interests of

the child.” In re J.T., 2024 IL App (1st) 232041, ¶ 67. The trial court is best positioned to

determine a child’s best interests, and we afford such decisions “broad discretion and great

deference.” In re E.S., 324 Ill. App. 3d 661, 667 (2001). “[A] dispositional order entered in a

proceeding under the [Act] is a matter committed to the sound discretion of the court.” In re

Beatriz S., 267 Ill. App. 3d 496, 500 (1994). “The court’s decision will be reversed only if the

findings of fact are against the manifest weight of the evidence or the court committed an abuse

of discretion by selecting an inappropriate dispositional order.” In re J.W., 386 Ill. App. 3d 847,

856 (2008). “A decision is against the manifest weight of the evidence when the opposite

conclusion is clearly apparent.” In re Ta. T., 2021 IL App (4th) 200658, ¶ 48. “[A]n abuse of

discretion occurs where the trial court’s decision is arbitrary, fanciful, or unreasonable to the

degree that no reasonable person would agree with it.” People v. McDonald, 2016 IL 118882,

¶ 32.

¶ 27 B. Neglect Findings

¶ 28 First, Tiffany asserts the trial court erred in finding Shy. R., Sham. R., J.R., and

Shan. R. were neglected. “Generally, neglect is defined as the failure to exercise the care that the

-7- circumstances justly demand.” (Internal quotation marks omitted.) In re R.S., 382 Ill. App. 3d

453, 460 (2008). “Neglect also encompasses wilful as well as unintentional disregard of duty.”

(Internal quotation marks omitted.) R.S., 382 Ill. App. 3d at 460. “[T]he term injurious

environment has been interpreted to include the breach of a parent’s duty to ensure a safe and

nurturing shelter for his or her children.” (Internal quotation marks omitted.) In re Arthur H., 212

Ill. 2d 441, 463 (2004). In any hearing under the Act, “proof of the abuse, neglect or dependency

of one minor shall be admissible evidence on the issue of the abuse, neglect or dependency of

any other minor for whom the respondent is responsible.” 705 ILCS 405/2-18(3) (West 2024).

“[W]hen faced with evidence of prior neglect by parents, ‘the juvenile court should not be forced

to refrain from taking action until each particular child suffers an injury.’ ” Arthur H., 212 Ill. 2d

at 477 (quoting In re Brooks, 63 Ill. App. 3d 328, 339 (1978)).

¶ 29 The evidence showed Tiffany battered T.R. in front of the younger children

before eventually kicking her out of the vehicle on the side of the interstate without a cell phone

or shoes. After the altercation, T.R.’s eyes were bloodshot, her eyes and face were swollen, and

her face, arms, and hands were bloodied. According to the integrated assessment, there were

ongoing concerns regarding Tiffany’s parenting practices and impulse control. Tiffany expressed

limited remorse for her actions or appreciation for the seriousness of the altercation, which

demonstrated a lack of accountability or emotional awareness. That lack of accountability

persisted throughout the proceedings below, as Tiffany repeatedly asserted T.R. instigated the

altercation. On appeal, Tiffany insists that “[t]he evidence reflected a mutual altercation,” further

demonstrating a lack of accountability. We are not interested in who started the fight—our

concern lies with the children’s best interests. See J.T., 2024 IL App (1st) 232041, ¶ 67. The

evidence presented was sufficient to demonstrate Tiffany failed to exercise the care demanded by

-8- the circumstances, and she failed to provide her children with a safe and nurturing environment.

See R.S., 382 Ill. App. 3d at 460; Arthur H., 212 Ill. 2d at 463. Accordingly, the court’s neglect

findings were not manifestly erroneous because the opposite conclusion was not clearly evident.

See A.P., 2012 IL 113875, ¶ 17.

¶ 30 C. Dispositional Orders

¶ 31 Second, Tiffany argues the trial court’s dispositional orders making Shy. R.,

Sham. R., J.R., and Shan. R. wards of the court and placing their guardianship with DCFS were

not supported by an adequate factual basis. Tiffany fails to cite any authority supporting this

argument, and she references a small portion of the evidence in the record in the most general

terms. The irony is not lost on us.

¶ 32 During the dispositional hearing, “the trial court determines whether it is

consistent with the health, safety, and best interests of the minor and the public that the minor be

made a ward of the court. [Citation.] At this point, the trial court may consider the acts and/or

omissions of the parents.” In re Z.L., 2021 IL 126931, ¶ 60. According to the dispositional

hearing report, the younger children were initially removed from Morrio’s care due to concerns

regarding his minimization of the altercation and his failure to demonstrate protective factors.

Although they were eventually returned to his care, and Tiffany was granted supervised contact,

the report recommended Tiffany and Morrio complete several services to achieve reunification.

Considering the circumstances leading to the minors being taken into care in the first place, the

court’s recommendations were very reasonable. Tiffany did not object to any of the report’s

recommendations, and Morrio only objected to the recommendation that he complete mental

health services. The court approved the report’s recommendations, with the exception of

Morrio’s mental health treatment requirement, and made all five children wards of the court. The

-9- younger children remained with Morrio, while T.R. remained in her foster placement. The court

set independence as T.R.’s goal and reunification as the younger children’s goals. Ensuring

minimal compliance before returning the children to the unfettered supervision of their parents

was not unreasonable. Based on the record before us, we cannot say the court’s dispositional

orders were an abuse of discretion, as they were not arbitrary, fanciful, or unreasonable. See

Beatriz S., 267 Ill. App. 3d at 500; McDonald, 2016 IL 118882, ¶ 32.

¶ 33 III. CONCLUSION

¶ 34 For the reasons stated, we affirm the trial court’s judgment.

¶ 35 Affirmed.

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