In re J.M.

Illinois Appellate Court
Civil Court
Indian Child Welfare Act
Citation
Case Number: 
2026 IL App (1st) 251802
Decision Date: 
Wednesday, September 30, 2026
District: 
1st Dist.
Division/County: 
1st Div./Cook Co.
Holding: 
Affirmed.
Justice: 
COBBS

Respondent appealed from an order of the circuit court adjudging respondent’s minor children to be abused and neglected and adjudging them to be wards of the court. On appeal, respondent argued that the circuit court erred because it failed to satisfy the Indian Child Welfare Act’s clear and convincing evidence. Respondent also argued that the circuit court’s finding that DCFS made active efforts to prevent the breakup of the family was against the manifest weight of the evidence. The appellate court affirmed, finding that the court properly followed the procedural framework of the Act and that its dispositional order was not against the manifest weight of the evidence. (FITZGERALD SMITH and HOWSE, concurring)