Illinois Appellate Court
Civil Court
Termination of Parental Rights
Court found Respondent-father to be unfit parent and terminated his parental rights as to one minor; and found him unfit parent as to another minor, but terminated his legal relationship with that minor based on previous showing that he is not the biological father of that minor. State failed to comply with Indian Child Welfare Act (ICWA) by not providing adequate notice to Respondent's Native American Tribe of the foster care and parental termination proceedings. As record as supplemented has only the responses from the Tribe and not the State's notice to them, notice is deemed insufficient. Presumption of paternity as to a child born during marriage is through verified complaint to declare non-existence of parent and child relationship brought by child, natural mother, or presumed father.(O'BRIEN, concurring; WRIGHT, specially concurring.)