In re Adoption of D.R., 2019 IL App (4th) 180603-U

- Case citation and parties
In re Adoption of D.R., 2019 IL App (4th) 180603-U. Petitioners-Appellees: Jathan P. & Kristin P. (prospective adoptive parents). Respondent-Appellant: Timierra J. (biological mother).

- Key legal issues
1) Whether the trial court’s finding that respondent was an “unfit person” under the Adoption Act (750 ILCS 50/1(D) — including §§ (a), (a‑1), (a‑2), (b), (c), (h), (k), (l), (o)) was against the manifest weight of the evidence; and 2) whether termination of respondent’s parental rights was contrary to the child’s best interests.

- Holding / Outcome
The Fourth District affirmed. The appellate court held the trial court’s unfitness finding (particularly under §§ 1(D)(b) and 1(D)(l)) and its best‑interests decision were not against the manifest weight of the evidence; parental rights were terminated.

- Significant legal reasoning (concise)
The court deferred to the trial court’s factual findings and application of the clear‑and‑convincing standard for unfitness. Evidentiary highlights supporting unfitness included: respondent’s execution of a preliminary consent to adoption and appointment of petitioners as short‑term guardians; respondent’s failure to participate or appear in the guardianship proceeding and in a later petition to discharge the guardianship; lack of registration with the putative‑father registry; alleged failure to obtain prenatal care, alleged drug use (infant tested positive for marijuana and withdrawal symptoms were observed), and failure to provide physical or monetary support despite employment. The trial court properly took judicial notice of the guardianship docket entries. After finding unfitness, the court considered best‑interest factors (stability, parent‑child relationship, petitioners’ long‑term care) and reasonably concluded termination favored the child’s welfare. The appellate court emphasized that the record supported the trial court’s credibility assessments and factual conclusions.

- Practice implications for attorneys
- Preliminary consents and short‑term guardianship appointments can be strong evidence of relinquishment or abandonment if later coupled with non‑participation in guardianship or adoption proceedings.
- Failure to appear and to register with the putative‑father registry is a significant procedural and substantive risk to parental rights.
- Medical records and contemporaneous communications (texts, physician observations) can be decisive in unfitness/best‑interest hearings.
- Judicial notice of related guardianship filings is proper and impactful.
- Remember the bifurcated process: clear‑and‑convincing proof of unfitness first; only then best‑interests determination.
- Note: opinion issued under Rule 23 — nonprecedential except as allowed by Rule 23(e)(1).