In re Z.L.

Illinois Appellate Court
Civil Court
Abuse and Neglect
Citation
Case Number: 
2020 IL App (1st) 200151
Decision Date: 
Monday, December 28, 2020
District: 
1st Dist.
Division/County: 
Cook Co., 1st Div.
Holding: 
Vacated and remanded.
Justice: 
WALKER

Court made Respondent mother's 4 children wards of the court and found her to be an unfit mother. Order must be vacated, and remanded to trial court to send notice to Bureau of Indian Affairs and any Native American tribes or nations with potential relationships with the children. State presented no evidence as to the parents' treatment of 3 of their children, but relied exclusively on the doctrine of anticipatory neglect. Evidence that the father, who no longer resides with mother, may have injured infant, when mother left infant in father's care, does not show that mother neglected or abused her children. State did not prove that minors suffered neglect or abuse, but record shows that childrent suffered from the order separating them from their mother. (HYMAN and PIERCE, concurring.)