Background
The State petitioned in October 2025 to have J.H. adjudicated neglected, alleging that his home lacked running water for weeks, his mother, Cassey R., used methamphetamine, and domestic violence occurred between her and an ex-boyfriend. The circuit court placed J.H. in DCFS temporary custody.
At the adjudicatory hearing, Cassey R. admitted using methamphetamine and testing positive 14 times while on probation between May 2024 and November 2025. She also acknowledged the lack of running water, a domestic-violence incident in which she was injured, and a truancy letter concerning J.H. She left the courtroom during the State’s closing argument. The court found J.H. neglected and, after denying counsel’s request to continue the disposition, found Cassey R. unfit and made J.H. a ward of the court.
The Court’s Holding
The appellate court granted appointed counsel’s Anders motion to withdraw and affirmed. It held that no nonfrivolous appellate issue existed concerning the neglect adjudication. The evidence of repeated methamphetamine use, unsafe housing conditions, domestic violence, and truancy supported the circuit court’s finding, even though Cassey R. denied using drugs in J.H.’s presence.
The court also found no arguable error in denying a continuance after Cassey R. voluntarily left the hearing despite being warned that doing so could waive rights. Finally, the dispositional findings were supported by evidence that she had not verified substance-abuse treatment, missed five requested drug drops, and had unresolved substance-use, domestic-violence, and parenting concerns.
Key Takeaways
- Anders withdrawal procedures apply in Illinois Juvenile Court Act appeals.
- Evidence of a parent’s substance use, unsafe living conditions, domestic violence, and a child’s truancy can support a neglect finding.
- A parent who voluntarily leaves a proceeding after a warning does not automatically establish good cause for a continuance.
Why It Matters
The order illustrates the deferential review of juvenile neglect and dispositional findings where the record supports concerns about a parent’s ability to provide safe and stable care. It also confirms that an appellate court may grant counsel leave to withdraw when the record presents no issue of arguable merit.