In re M.M.

Illinois Appellate Court
Civil Court
Termination of Parental Rights
Citation
Case Number: 
2022 IL App (1st) 211505
Decision Date: 
Friday, May 13, 2022
District: 
1st Dist.
Division/County: 
6th Div./Cook Co.
Holding: 
Reversed and remanded.
Justice: 
ODEN JOHNSON

Respondent, an incarcerated parent, claimed on appeal that her due process rights were violated when she was expelled from a dispositional hearing held remotely at which the trial court found her unable and unwilling to care for her minor child. Respondent also argued that the trial court failed to sufficiently inquire into her pro se claim that her counsel was ineffective. The appellate court reversed and remanded, finding that removing respondent from the hearing without first exploring other options for viewing or attending the proceedings was not consistent with statutory requirements or due process. (HARRIS and MIKVA, concurring)