In re K.D.

This appeal arose from the termination of Rebecca D.'s parental rights to her two children, K.D. and K.L., following adjudications of neglect and dispositional orders making them wards of the court. On the day set for the termination trial, respondent orally requested a continuance, which the trial court denied. After conducting unfitness and best-interests hearings, the trial court found respondent unfit and terminated her parental rights. Respondent's sole argument on appeal was that the trial court abused its discretion by denying her continuance request.

The Fourth District affirmed, applying Illinois Supreme Court Rule 901(c), which requires a showing of good cause for continuances in juvenile proceedings and emphasizes consistency with the child's best interests. The court reiterated that parties have no absolute right to a continuance, that day-of-trial requests demand especially persuasive justification, and that such requests are disfavored due to potential disruption to witnesses, parties, and the court. Respondent had known the trial date for over two months and had more than five months since the termination motions were filed to prepare, yet she never identified specific witnesses or evidence she intended to present. The court distinguished cases cited by respondent involving much shorter preparation windows and identified, indispensable witnesses, and instead found the case analogous to In re D.M., where a similarly vague, untimely continuance request was properly denied. The court also stressed the Juvenile Court Act's policy favoring prompt resolution to avoid harm to children who had already spent significant time in care.

For practitioners, this decision reinforces that courts will closely scrutinize last-minute continuance requests in termination proceedings and require concrete, documented reasons—not generalized unpreparedness—to justify delay.