In re William H.

Illinois Appellate Court
Civil Court
Termination of Parental Rights
Citation
Case Number: 
No. 1-10-2563
Decision Date: 
Friday, March 4, 2011
District: 
1st Dist.
Division/County: 
Cook Co., 5th Div.
Holding: 
Affirmed.
Justice: 
FITZGERALD SMITH
Court entered orders adjudging minor child a ward of court and holding that reasonable efforts had been made to prevent or eliminate the need for removal of the minor from the home. Major obstacle to reunification efforts was that minor did not want to have any contact with respondent mother, who had history of alcohol abuse and domestic violence in home, and minor became fearful and anxious upon discussing her. More than ample evidence was presented to show reasonable efforts had been undertaken. "Best interest" analysis is key to wardship decision, not a finding as to whether reasonable efforts toward reunification were employed. Child's best interest takes precedence over any other consideration, including natural parents' right to custody. (HOWSE and EPSTEIN, concurring.)