In re T.J.

Illinois Appellate Court
Civil Court
Adjudication of Wardship
Citation
Case Number: 
2026 IL App (1st) 242406
Decision Date: 
Wednesday, March 25, 2026
District: 
1st Dist.
Division/County: 
2d Div./Cook Co.
Holding: 
Vacated and remanded.
Justice: 
ELLIS

Respondent appealed from a circuit court adjudication of wardship of a minor child in a medical neglect case, arguing that the court improperly admitted a child abuse and proactive services report under the business records exception to the hearsay rules, that the finding of neglect at the adjudicatory hearing was against the manifest weight of the evidence, and that the court erred in finding that respondent violated an order of protection. The appellate court vacated the trial court orders finding the minor neglected and the respondent in violation of a protective order and remanded for a new adjudicatory hearing, explaining that it agreed with the respondent’s argument that the hearing was “rushed, vague, and incomplete” and that it did not constitute a true adversarial hearing where the State did not put on sufficient substantive evidence and where the circuit court ruled in favor of the State minutes after the admission of nearly 5,000 pages of medical records. (D.B. WALKER, concurring and VAN TINE, dissenting)