In re J.S.

Illinois Appellate Court
Civil Court
Indirect Civil Contempt
Citation
Case Number: 
2022 IL App (1st) 220083
Decision Date: 
Wednesday, November 30, 2022
District: 
1st Dist.
Division/County: 
5th Div./Cook Co.
Holding: 
Reversed.
Justice: 
CUNNINGHAM

Consolidated appeals of 10 cases arising from the circuit court’s orders finding the director of DCFS in indirect civil contempt of court for not finding appropriate placements for each of the minors in question as ordered by the circuit court. On appeal, the director argued that the circuit court erred by finding that he should be held in indirect civil contempt, by finding that a consent decree entered in an unrelated case did not bar the court from finding him in contempt, and by finding that a proposed placement did not purge the contempt finding because the court found it was not an appropriate placement. The appellate court reversed the judgments of the circuit court, finding that the evidence did not support a conclusion that the director “willfully ignored” the trial court’s orders merely because DCFS’s efforts to find appropriate placements for the children were ineffective and lacked an appropriate sense of urgency. (HOFFMAN and DELORT, concurring)