Fifth District Appellate Court

Adoption of Mariya N.

December 16, 2025
2025 IL App (5th) 250586-U
Adoption
Case Analysis
1) Case citation and parties
- In re Adoption of Mariya N. and Seth N., No. 5-25-0586, 2025 IL App (5th) 250586‑U (Ill. App. Ct., 5th Dist., Dec. 16, 2025).
- Petitioners/Appellees: Devon N. and Jessica N. (husband and wife; Devon is biological father).
- Respondent/Appellant: Erica W. (mother).
- Trial court: Circuit Court of Christian County, No. 24‑AD‑13 (Judge Christopher B. Hantla).

2) Key legal issues
- Whether the trial court’s finding that respondent was an “unfit person” under the Adoption Act (750 ILCS 50/1) was against the manifest weight of the evidence (grounds asserted: failure to maintain a reasonable degree of interest/concern/responsibility, §50/1(D)(b), and intent to forgo parental rights via 12‑month noncontact, §50/1(D)(n)).
- Whether termination of respondent’s parental rights and granting of adoption was in the children’s best interests.

3) Holding/outcome
- Affirmed. The appellate court held the trial court’s findings of unfitness and that termination was in the children’s best interests were not against the manifest weight of the evidence; adoption granted to Devon and Jessica.

4) Significant legal reasoning (concise)
- Standard of review: unfitness and best‑interest findings reviewed for manifest weight of the evidence; trial court afforded deference as fact‑finder.
- Evidence: respondent admitted she had not seen the children since 2019, made essentially no contact (no letters, gifts, support) and only one message to father after completing drug court; respondent testified her addiction prevented contact. DCFS involvement and a 2019 parenting order and a guardian ad litem report supported termination. Petitioners presented school records and testimony showing children’s stability and close bond with petitioners.
- Comparison to precedent: court distinguished In re Syck (mother made repeated attempts to contact and sent gifts) — here respondent’s minimal attempts and admitted abandonment supported unfitness. Rehabilitation (completion of drug court) without active, documented efforts to reestablish relationship was insufficient to defeat the statutory grounds.
- Because any one statutory ground sufficed and the best‑interest factors favored stability with petitioners, the appellate court affirmed.

5) Practice implications
- For parents seeking to preserve parental rights: document and sustain regular, verifiable contact (calls, texts, letters, gifts, court filings) and promptly pursue visitation petitions; document attempts and any obstruction by the custodial parent. Completion of treatment programs is important but must be coupled with concrete steps to reengage with the child.
- For prospective adoptive/custodial parents: compile school records, GAL reports, records of noncontact/support, DCFS files, and witness testimony proving stability and child welfare.
- For counsel: focus proof on statutory elements (12‑month noncontact, objectively unreasonable lack of interest), preserve evidence of attempts/obstruction, and emphasize child stability in best‑interest argument.
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