In re Adoption of H.A.

1. Case citation and parties
- In re Adoption of H.A., 2025 IL App (4th) 250345-U (Ill. App. Ct. 4th Dist. Nov. 21, 2025) (Sup. Ct. R. 23 order — not precedent except in limited circumstances).
- Respondent-Appellant: Talib A. (biological father). Petitioners-Appellees: Lisa C. and Bill C. (maternal grandparents seeking to adopt after the mother’s death).

2. Key legal issues
- Whether respondent was unfit as a matter of law and fact under the Illinois Adoption Act such that his consent to adoption was unnecessary (750 ILCS 50/1(D)(d), (h) cited by the trial court).
- Standard of proof at the stage-one hearing (clear and convincing evidence of unfitness) and the appropriate appellate standard (manifest weight of the evidence).

3. Holding/outcome
- The Fourth District affirmed the trial court: the finding of parental unfitness was not against the manifest weight of the evidence. The trial court later terminated parental rights (best-interest determination on March 11, 2025), and that outcome was preserved by the affirmed unfitness finding.

4. Significant legal reasoning (concise)
- The appellate court deferred to the trial court’s credibility determinations and factual findings. The record contained multiple indicia supporting statutory unfitness: prior domestic battery arrests/convictions (including a guilty plea), citations for child endangerment, obstructing service of process, documented police welfare checks showing injury to the child’s mother, and testimony that respondent interfered with service and contact.
- Additional evidence showed respondent’s limited parental involvement post-incidents (failure to know basic child information, no school engagement, no child support), admission of a trespass notice, and contested but admitted text-message evidence. The court found the cumulative evidence met the clear-and-convincing threshold.
- The opinion emphasizes appellate deference: where the factfinder resolves conflicting memories and credibility, reversal requires manifest injustice — absent here.

5. Practice implications for family-law attorneys
- In adoption/termination matters premised on unfitness, compile a multi-faceted record: police reports, convictions/plea records, welfare-check testimony, DCFS contacts, school and medical records, proof of interference with service, financial support history, and contemporaneous electronic messages. Robust foundation for digital evidence is critical.
- Expect courts to credit conduct showing domestic violence, obstruction, and lack of parental involvement as cumulative proof of unfitness. Preserve objections to evidentiary foundation and venue, but recognize appellate deference to trial credibility findings.
- For petitioners (prospective adopters), consider advancing adoption when statutory unfitness is evident rather than waiting for separate parenting-time/allocation litigation. For respondents, immediate, documented post-incident parental engagement (support, school involvement, consistent visitation) is essential to rebut unfitness claims.