In re T.T.

CourtAppellate Court of Illinois
DecidedApril 17, 2026
Docket1-25-1928
StatusUnpublished

This text of In re T.T. (In re T.T.) 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 T.T., (Ill. Ct. App. 2026).

Opinion

2026 IL App (1st) 25-1928-U No. 1-25-1928 Order filed April 17, 2026 Fifth Division

NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1). ______________________________________________________________________________ IN THE APPELLATE COURT OF ILLINOIS FIRST DISTRICT ______________________________________________________________________________ In re T.T., a Minor, ) Appeal from the ) Circuit Court of (The People of the State of Illinois, ) Cook County. ) Petitioner-Appellee, ) No. 23 JA 00806 ) v. ) Honorable ) Diane M. Pezanoski, L.K., ) Judge, Presiding. ) Respondent-Appellant.) )

JUSTICE ODEN JOHNSON delivered the judgment of the court. Presiding Justice Mitchell and Justice Mikva concurred in the judgment.

ORDER

¶1 Held: We affirm where the court’s finding of a lack of reasonable progress towards reunification during either of two separate nine-month periods was not against the manifest weight of the evidence.

¶2 Respondent mother L.K. appeals from the circuit court’s determination that termination of

her parental rights was minor child’s best interests. On appeal, respondent contends that the trial No. 1-25-1928

evidence was insufficient to prove by clear and convincing evidence that she had neglected the

minor on the statutory grounds alleged in the termination petition when she was drug-free and

visiting the minor at the time of the unfitness hearing. For the reasons that follow we affirm.

¶3 I. BACKGROUND

¶4 A. Adjudication Proceedings

¶5 The majority of the underlying facts are not in dispute. The record reveals that the minor,

T.T., was born on November 1, 2023, with drugs in her system. The State filed a petition for

adjudication of wardship on November 15, 2023, alleging that respondent had neglected and/or

abused the newborn minor. In support of that allegation, the State alleged that respondent had a

long history of drug abuse and used illicit drugs while pregnant. At birth, the minor tested positive

for cocaine, fentanyl, and opiates. Respondent was previously involved in incidents of alleged

abuse and showed signs of physical injury; respondent was homeless at that time; and T.T.’s

paternity was not established. The petition alleged that those conditions created an injurious

environment to the minor and put her at risk of serious physical injury.

¶6 After a hearing on March 27, 2024, the circuit court entered an order which adjudicated the

minor an abused or neglected child pursuant to sections 2-3(1)(b), (c) and 2-3(2)(ii) of the Juvenile

Court Act of 1987 (Act) (705 ILCS 405/2-3(1)(b), (c); 2-3(2)(ii) (West 2022)), The adjudication

was based on the fact that she was a minor under 18 years of age whose environment was injurious

to her welfare, she was exposed to drugs as an infant, and there was a substantial risk of physical

injury. After the adjudication hearing, the circuit court held a dispositional hearing where it found

respondent to be unable to care for the minor. The unknown father was found unable and unwilling,

-2- No. 1-25-1928

and the minor was adjudged a ward of the court and placed under guardianship of the Department

of Children and Family Services (DCFS).

¶7 B. Permanency Orders

¶8 A permanency order entered on the same day noted that respondent had recently checked

herself into an in-patient substance abuse treatment program with Southwood Interventions. The

order further noted that respondent was not visiting consistently and had not made substantial

progress towards the return home of the minor. The permanency goal at that time was return home

within 12 months. The next permanency hearing was held on September 25, 2024, and the goal

for the minor was changed to return home pending status.

¶9 Following the September 2024 permanency hearing, the State filed a motion to reconsider,

arguing that the circuit court erred in denying the request of the State and the Guardian ad litem

(GAL) to change the goal to substitute care pending a court determination on termination of

parental rights. The circuit court denied the motion on October 30, 2024, finding that it could not

change the goal to substitute care pending court determination of parental rights sooner than nine

months after the adjudication findings without a hearing and a finding allowing the early

termination of reasonable efforts. As part of that ruling, the circuit court noted that at a status

hearing on May 29, 2024, the caseworker testified that she had scheduled three in-person and one

Zoom visit between respondent and the minor in April and May of 2024. On the day of each

scheduled visit, respondent did not appear despite previously confirming the visits. Additionally,

the caseworker testified that respondent called her from the hospital using a hospital phone and

they spoke about reunification services. Respondent expressed that she planned to go to an in-

patient program after discharge from the hospital. When the caseworker attempted to follow up,

-3- No. 1-25-1928

the service provider stated that it could not provide any information without a signed release of

information. Ultimately, no records of respondent’s participation in that substance abuse program

were submitted.

¶ 10 On January 29, 2025, the circuit court entered a permanency order changing the goal for

the minor to substitute care pending court determination of termination of parental rights. The

order found that all other goals had been ruled out and that respondent made no progress in

reunification services. The same day, respondent’s counsel filed a motion to withdraw stating that

she had no meaningful communication with respondent. However, the circuit court did not rule on

the motion to withdraw, and her counsel represented respondent through the filing of the notice of

appeal.

¶ 11 C. Petition for Termination of Parental Rights

¶ 12 On March 25, 2025, the State filed a supplemental petition for the appointment of a

guardian with the right to consent to adoption (TPR petition), requesting termination of

respondent’s parental rights under the Adoption Act (750 ILCS 50/1 et seq. (West 2022)). The

petition alleged that respondent was unfit based on four grounds of abuse and neglect: (1) failure

to maintain a reasonable degree of interest, concern or responsibility as to the child’s welfare (750

ILCS 50/1(D)(b) (West 2022)); (2) desertion of the child for more than three months preceding

the commencement of the termination proceedings (id. 50/1(D)(c); (3) failure to make reasonable

efforts to correct the conditions that were the basis for the child’s removal, or failure to make

reasonable progress towards the return of the child (id. 50/1(D)(m); and (4) intent to forego

parental rights as manifested by the failure to visit the child, failure to communicate with the

agency, and/or failure to maintain contact or plan for the child (id. 50/1(D)(n)). The petition alleged

-4- No. 1-25-1928

two nine-month timeframes for respondent’s failure to make reasonable efforts or reasonable

progress under section 50/1(D)(m), March 27, 2024, through December 27, 2024, and June 25,

2024, through March 25, 2025.

¶ 13 On August 27, 2025, the circuit court conducted an unfitness hearing, a best interest

hearing, and a permanency hearing via Zoom.

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Related

People v. Diane N.
752 N.E.2d 1030 (Illinois Supreme Court, 2001)
People v. Lashawn F.
802 N.E.2d 800 (Illinois Supreme Court, 2003)
In re Nicholas C.
2017 IL App (1st) 162101 (Appellate Court of Illinois, 2017)
In re K.P.
2020 IL App (3d) 190709 (Appellate Court of Illinois, 2020)
In re J.S.
2020 IL App (1st) 191119 (Appellate Court of Illinois, 2021)
In re Ta. T.
2021 IL App (4th) 200658 (Appellate Court of Illinois, 2021)
In re J.W.
2024 IL App (1st) 231918 (Appellate Court of Illinois, 2024)

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In re T.T., Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-tt-illappct-2026.