In re Y.C.

In this Rule 23 order, the Fourth District addressed an appeal from a trial court's termination of Kayla D.'s parental rights to her four children, who had been placed in DCFS custody following neglect petitions filed in November 2023. After a fitness hearing Kayla did not attend and a best-interests hearing she did attend, the trial court found her unfit and concluded termination served the children's best interests. Kayla's appellate counsel moved to withdraw under Anders v. California and In re S.M., asserting no meritorious issue existed for appeal.

The appellate court agreed and granted counsel's motion to withdraw, affirming the trial court in full. On unfitness, the court found ample evidence that Kayla failed to make reasonable efforts or reasonable progress during the relevant nine-month periods under 750 ILCS 50/1(D)(m)(i)-(ii): she completed none of her recommended services, was rated unsatisfactory on every service plan, tested positive for THC, denied needing services, and had no contact with the children since mid-2025. On best interests, the court emphasized the children's stability, attachment to and integration with their foster family, and expressed desire for adoption, concluding their need for permanence outweighed further delay. Finally, the court held the denial of a continuance for the fitness hearing—prompted by Kayla's unexplained absence—was not an abuse of discretion because her counsel still cross-examined witnesses and argued on her behalf, and no prejudice resulted.

For practitioners, this order illustrates the evidentiary threshold courts apply in reviewing unfitness and best-interests findings for manifest-weight challenges, and confirms that a parent's absence from a fitness hearing, without more, does not automatically warrant a continuance or establish prejudice on appeal.