Illinois Appellate Court
Civil Court
Termination of Parental Rights
Respondent mother's parental rights were terminated as to four of her ten children, based on allegations that mother's sister, who was guardian of minors, inflicted excessive corporal punishment on them. At dispositional hearing, Assistant PD identified herself as in for a colleague of behalf of CASA, which had been appointed as GAL for children. As same Assistant PD had appeared on behalf of mother for nearly two years, beginning with first permanency hearing, per se conflict of interest requires reversal of termination. Per se nature of rule requires no proof of prejudice, as presumed prejudice arises from divided loyalties entailed by representing more than one party in a proceeding. (HUTCHINSON and SCHOSTOK, concurring.)