In re Jamari R.

Illinois Appellate Court
Civil Court
Termination of Parental Rights
Citation
Case Number: 
2016 IL App (1st) 160850
Decision Date: 
Friday, September 30, 2016
District: 
1st Dist.
Division/County: 
Cook Co., 4th Div.
Holding: 
Reversed and remanded.
Justice: 
HOWSE

Court entered order terminating parental rights of father. State's service by publication listed incorrect last name of minor and minor's mother. Thus, service by publication was defective because it did not substantially comply with Section 16-2 of Juvenile Court Act, and thus did not confer trial court with personal jurisdiction over the father. THus, notice of publication was not sufficient to confer trial court with personal jurisdiction over the father, and all orders entered in case prior to the father's appearance are void. Father's appearance resulted only in prospective waiver of service and personal jurisdiction over him, and did not retroactively waive those objections and validate orders entered prior to his appearance. (McBRIDE and BURKE, concurring.)