K.O. filed a petition for an order of protection against Fernando Olea in McHenry County Circuit Court, alleging harassment under the Illinois Domestic Violence Act of 1986. After the trial court denied an emergency order, a full hearing was held on October 30, 2025, at which petitioner testified credibly and without rebuttal. The court granted a two-year plenary order of protection, finding respondent's conduct constituted harassment in three statutory categories: creating a disturbance at petitioner's workplace by e-mailing her employer, improperly concealing a minor child and repeatedly threatening to remove minor children, and threatening physical force. Respondent appealed, arguing the order was against the manifest weight of the evidence, that the court relied on matters outside the record, and that the remedies were an abuse of discretion.

The Second District affirmed on all three issues. Because petitioner's testimony was credible and unrebutted, and because the Act presumes emotional distress from the identified categories of conduct absent rebuttal by a preponderance of the evidence, the manifest weight standard was satisfied. The court rejected respondent's evidentiary arguments, finding hearsay and foundation objections forfeited due to his failure to object at trial, and holding that a DCFS investigation respondent himself introduced on cross-examination lacked sufficient detail to undermine petitioner's case. The court also found no abuse of discretion in the remedies fashioned.

This decision reinforces that respondents in IDVA proceedings bear the burden of rebutting the statutory presumption of emotional distress and must preserve evidentiary objections at trial or forfeit them on appeal. It also confirms that an inappropriate e-mail to a party's employer causing a policy change can constitute a workplace disturbance under section 103(7)(i).

April Moore filed suit in Madison County, Illinois, alleging that Sherry Radae violated the Illinois Alienation of Affections Act by alienating the affections of Moore's spouse. After six-and-a-half years of pretrial litigation, the case proceeded to a bench trial in December 2023. The trial court entered judgment for the defendant in May 2024, finding that the most significant events supporting the claim occurred in Missouri and other states, that the marriage was localized in Ohio, and that the Act had no extraterritorial effect. Moore appealed, and Radae filed a conditional cross-appeal.

The Fifth District affirmed on all issues. The court held that Illinois statutes have no extraterritorial effect unless the legislature expresses a clear intent through an express statutory provision, and that a general liberal construction clause does not satisfy that requirement. The court further held that extraterritorial effect is a canon of statutory construction — not a party argument — and therefore the trial court properly raised it sua sponte without implicating forfeiture principles. Applying the Avery 'primarily and substantially' standard, the court found that all three elements of the alienation of affections claim — love and affection, damages, and overt acts of seduction — were grounded primarily in Ohio, Missouri, and other states, with only three to four Illinois rendezvouses and no evidence of seductive conduct occurring there.

For practicing attorneys, this decision clarifies that Illinois courts will independently assess extraterritorial effect in statutory claims regardless of whether the parties raise the issue, and that a plaintiff relying on an Illinois statute must demonstrate that the bulk of the relevant conduct occurred within Illinois.

WP Venture 4 LLC (WP4) sued Luther Village Owners Corporation (LVOC) to enforce a rent formula in a 99-year Cooperative Ground Lease, seeking back rent calculated at a rate LVOC contended was approximately 50% higher than the parties intended. LVOC counterclaimed for reformation based on mutual mistake. The trial court granted summary judgment for WP4 and third-party defendant Lutheran Home for the Aged (LHA), holding LVOC's reformation claim was time-barred by the 10-year statute of limitations and independently barred by estoppel certificates LVOC signed in 2018 and 2019. The trial court entered a final judgment awarding WP4 $6,426,339.30 in back rent. LVOC appealed.

The appellate court reversed on both grounds. First, it held that the discovery rule — not the execution rule — governs accrual of mutual-mistake reformation claims, reasoning that a party cannot seek reformation until it learns of the mistake. Because the record contained genuine disputes of material fact as to when LVOC knew or should have known of the alleged error — including decades of LHA's own communications confirming rent as 10% of FMV — the limitations question could not be resolved as a matter of law. Second, the court held the estoppel certificates were ambiguous: they listed rent amounts consistent with LVOC's position and confirmed no default, yet neither certificate mentioned the rent-multiplier dispute despite WP4's pre-execution awareness of it.

The court remanded for the trial court to address unresolved alternative grounds including equitable estoppel, laches, and LVOC's burden of proof on reformation. For practitioners, this decision underscores that estoppel certificates must specifically identify known disputes to be effective waivers, and that reformation claims accrue under the discovery rule in Illinois.

Plaintiff Olivia Aguilar filed a negligence action on March 10, 2025 in Cook County Circuit Court against Schindler Elevator Corporation and an employee, alleging she suffered a left shoulder injury on January 22, 2023 when an elevator door struck her. Defendants moved to dismiss under section 2-619(a)(5), arguing the action was time-barred under Illinois's two-year personal injury statute of limitations. The trial court granted the motion and dismissed the first amended complaint with prejudice. Plaintiff appealed, arguing the discovery rule should toll the limitations period because her preexisting chronic cervical spine condition masked her awareness of a distinct, actionable shoulder injury.

The Illinois Appellate Court, First District, affirmed. Applying de novo review, the court held that the sudden, traumatic event rule precluded application of the discovery rule. Because the elevator door unexpectedly struck plaintiff's shoulder and caused her immediate pain, the law presumes she was placed on notice of a potential injury and right of action on the date of the incident. Plaintiff's subjective belief that her pain stemmed from a preexisting condition did not negate her objective knowledge that the door caused immediate pain, which triggered her duty to inquire further.

This decision is significant for personal injury and defense counsel because it reinforces that a plaintiff's preexisting condition will not automatically invoke the discovery rule where a sudden, external traumatic event causes immediate, perceptible pain. Attorneys should counsel clients promptly following any traumatic incident, regardless of diagnostic uncertainty.

In Hendrick v. Hendrick, the Illinois Fifth District Appellate Court reversed the Champaign County circuit court's dismissal of count I of plaintiffs' third amended complaint, which alleged that co-trustee Bobbie Hendrick breached her fiduciary duties in administering two family trusts whose primary asset was Hendrick House, a family-owned corporation. Betsy Hendrick and Rebecca Rowe alleged that Bobbie orchestrated the installation of her husband Terrell Williams as president of Hendrick House, diverted trust resources to benefit her own household, packed the board with her children, excluded other beneficiaries from management, and allowed the corporation to operate at a loss for years while Bobbie, Terrell, and their children received compensation funded by borrowed money.

The appellate court held that all four alleged breaches — loyalty, impartiality, prudent administration, and good faith — were sufficiently pleaded to survive a section 2-615 motion to dismiss. On loyalty, the court applied the statutory presumption of conflict under section 802(b)(1) of the Illinois Trust Code, which arises when a trustee manages trust property through a transaction involving the trustee's spouse, placing the burden on Bobbie to rebut the presumption with clear and convincing evidence. On impartiality and prudent administration, the court found specific factual allegations regarding operational losses, failure to scrutinize Terrell's financial reports, and unequal distributions sufficient to preclude dismissal.

For trust litigators, this decision reinforces that Illinois's fact-pleading standard does not require exhaustive evidentiary detail at the pleading stage, and that the section 802(b)(1) spousal conflict presumption is a powerful tool for plaintiffs challenging trustee self-dealing involving a spouse placed in a management role over trust assets.

Dr. William Sullivan, an emergency physician, sued Allison Schiman, Rodney Perez, and Ally Anderson LLC for defamation per se, false light, and intentional infliction of emotional distress arising from a Facebook post falsely accusing Sullivan of sexually assaulting a patient during a medical examination, which Perez reposted and featured. Following a four-day bench trial in La Salle County, the circuit court found both Schiman and Perez liable for defamation per se and found that Sullivan suffered actual mental anguish—including sleep loss, embarrassment, and changes in patient care behavior—yet awarded only $1 in nominal damages against each defendant. The court also denied Sullivan's post-trial motion for sanctions under Illinois Supreme Court Rules 219(b) and 137 based on Perez's false responses to requests to admit.

The appellate court reversed on both issues. On damages, the court held that nominal damages are appropriate only when no actual, meaningful harm occurred. Because the trial court affirmatively found actual mental anguish, and because damages are presumed in defamation per se cases, the $1 award was legally inconsistent with those findings. The court vacated the nominal damages award and remanded for entry of a proper compensatory damages award, emphasizing that difficulty in calculating reputational harm does not render the injury uncompensable. On sanctions, the court held that the trial court abused its discretion by denying the Rule 219(b) motion without applying the rule's required three-part criteria—instead citing the 'stage of the game' and the breadth of Perez's deposition, neither of which are proper considerations under the rule.

For practicing attorneys, this decision reinforces that a finding of actual harm in a defamation per se case forecloses a nominal damages award, and that trial courts must rigorously apply Rule 219(b)'s enumerated criteria when ruling on sanctions motions for false denials of requests to admit.

This opinion from Rule 23 was filed on 2026-07-07. The case "Real Estate Naperville II, LLC v. E&S Management Group, LLC, 2026 IL App (3d) 250183" (Docket: 2026 IL App (3d) 250183) addresses important legal issues. Due to technical difficulties, the full AI summary is temporarily unavailable. Please review the full opinion for complete details.

LDR Cleaning & Restoration, Inc. sued Felicia Johnson for breach of contract arising from an unpaid water damage restoration project. After defendant's original counsel failed to respond to requests for admission and missed hearings, a default judgment was entered but later vacated when defendant appeared pro se. New counsel entered an appearance, but plaintiff ultimately obtained summary judgment for $56,317.50 based on the verified complaint, the parties' agreement, deemed-admitted requests for admission, and supporting affidavits. Defendant appealed pro se.

On appeal, defendant's opening brief challenged only the vacated default judgment and failed to comply with Illinois Supreme Court Rule 341(h), including by omitting a statement of facts and failing to cite pertinent authority. The court declined to strike the brief given the straightforward record but found all opening brief arguments meritless, as there was no default judgment in existence to contest. Defendant's reply brief raised entirely new arguments — including challenges to the summary judgment on grounds of disputed material facts, insufficient evidentiary support, and attorney abandonment — all of which the court held were forfeited under Rule 341(h)(7) because they were not raised in the opening brief.

Addressing the reply brief arguments in the alternative, the court found each independently meritless. Bare allegations of disputed facts without evidentiary support cannot defeat summary judgment. Defendant's attorney abandonment argument failed because the default judgment had already been vacated, the cited cases were inapplicable, and there is no constitutional right to effective assistance of counsel in civil proceedings.

Patricia Eads, as trustee of the William H. Dorman Trust, filed a quiet title action in Madison County alleging that a fence erected by defendant Amanda Abernathy in 2021 encroached on Trust property. After a bench trial, the circuit court entered judgment for defendant on December 14, 2023, finding plaintiff failed to meet her burden of proof. The court also found the action was frivolous and not brought in good faith, imposing Rule 137 sanctions sua sponte. The amount of attorney fees ($7,091) was determined at a December 16, 2024 hearing, and plaintiff filed her notice of appeal on January 15, 2025.

On appeal, the Fifth District affirmed on all issues. The court held it had jurisdiction because the December 14, 2023 order was not final while the Rule 137 fee amount remained pending and no Rule 304(a) finding had been entered, making the January 2025 notice of appeal timely. The court upheld the trial court's credibility determinations — particularly its rejection of plaintiff's key witness, who amended testimony mid-trial after Googling his equipment's accuracy — under the deferential manifest weight standard. The court further confirmed that Rule 137(a) expressly permits sua sponte sanctions, that no evidentiary hearing with sworn testimony was required to determine the fee amount, and that a detailed counsel proffer with opportunity for plaintiff to respond was sufficient.

This decision is significant for litigators because it clarifies that an unresolved Rule 137 sanctions claim suspends appellate finality, and that courts retain broad discretion to impose and quantify sanctions without formal motion practice or sworn fee testimony.

In November 2025, the State filed petitions in Tazewell County alleging minors A.P. and R.P. were neglected due to an injurious environment and that R.P. was abused through excessive corporal punishment by respondent-father Blaykdon P. In December 2025, respondent, through counsel, declined to respond to the petitions invoking his Fifth Amendment right against self-incrimination due to pending criminal litigation, and the trial court entered a default judgment against him. Following an adjudicatory hearing where the State presented evidence by proffer, the court found both minors neglected and R.P. abused. At the dispositional hearing, the court adjudicated the minors wards of the court, found respondent unfit, placed the minors with their mother, and entered a no-contact order against respondent. Respondent appealed, and appointed appellate counsel moved to withdraw pursuant to Anders v. California.

The Fourth District granted counsel's motion to withdraw, finding no meritorious issues on appeal. On the adjudicatory findings, the court held that the invited error doctrine precluded any challenge because respondent himself consented to the default judgment. Even absent that bar, the State's proffered evidence — documenting respondent's excessive corporal punishment of R.P. causing injuries, committed in A.P.'s presence — adequately supported the abuse and neglect findings under a preponderance standard. The court also found no basis for an ineffective assistance claim.

Regarding the dispositional no-contact order, the court found it expressly authorized by the Juvenile Court Act, supported by the evidence and the GAL's report, and provisional in nature. Critically, the court held any challenge was moot because respondent's existing criminal conditional release order already independently prohibited contact with the children, meaning appellate relief would provide no practical benefit. Practitioners should note the interplay between criminal conditional release conditions and juvenile court protective orders, and the application of invited error in default adjudication contexts.

Crystal Davis filed a petition for an emergency and plenary order of protection against Wayman Freelon under the Illinois Domestic Violence Act of 1986, alleging sexual assault and prior strangulation. The trial court issued an emergency order of protection, but after a bench trial on June 9, 2025, found Davis not credible, concluded she failed to prove abuse by a preponderance of the evidence, and denied and dismissed the petition. Davis appealed, challenging both the vacatur of a default plenary order of protection entered on April 23, 2025, and the ultimate denial of her petition.

The First District Appellate Court affirmed on a dispositive threshold ground: Davis failed to prove that Freelon qualified as a 'family or household member' under the Act. The court held that the parties' relationship — a short, secret, non-romantic, purely physical arrangement lasting just over one month that originated from a business inquiry — did not constitute a 'dating relationship' as contemplated by 750 ILCS 60/103(6). Relying on Alison C. v. Westcott, People v. Howard, and McClellan v. Hull, the court emphasized that a dating relationship requires a serious courtship with a significant romantic focus, not merely repeated sexual encounters. Because this finding was dispositive, the court declined to address Davis's arguments regarding the abuse finding, the vacatur of the default order, and alleged trial court errors, treating those issues as either unnecessary to resolve or moot.

For practitioners, this case reinforces that establishing subject matter eligibility under the IDVA — specifically, the 'family or household member' requirement — is a threshold issue that can defeat an order of protection petition regardless of the underlying abuse allegations. Attorneys should carefully assess the nature, duration, and character of the parties' relationship before filing.

Jesse Garmon was convicted of misdemeanor criminal sexual abuse in 1992 and later triggered sex offender registration obligations through a 2012 felony conviction. After his 2018 release, he registered and subsequently pleaded guilty to a Class 3 felony for failing to comply with registration requirements. In 2024, Garmon filed a declaratory judgment action in Fulton County Circuit Court arguing that the Sex Offender Registration Act (SORA) was unconstitutional as applied to him under the proportionate penalties clause of the Illinois Constitution, and seeking removal from the Registry. The trial court dismissed the complaint under section 2-615 for legal insufficiency, and Garmon appealed.

The Fourth District affirmed, holding that the registration requirements do not constitute punishment or a penalty — a necessary predicate to any proportionate penalties clause claim. The court applied the Illinois Supreme Court's controlling determination in Kopf v. Kelly, 2024 IL 127464, that SORA is not punitive in nature, reasoning that this conclusion does not change based on which constitutional provision frames the challenge. The court rejected Garmon's argument that post-Kopf statutory amendments rendered the scheme punitive, finding that the substantive restrictive provisions he cited predated Kopf and were already considered in that decision, while the actual post-Kopf amendments addressed only definitional changes, LEADS database functions, and name-change procedures — relatively minor adjustments insufficient to alter the statute's non-punitive character.

For practitioners, this decision forecloses proportionate penalties clause challenges to SORA by establishing that Kopf's non-punitive finding applies equally across constitutional theories, and that incremental legislative amendments will not easily reopen that question.

Arlene Staffeldt died testate in May 2023, and her sons Michael and Brandt Staffeldt were appointed independent co-executors. When they scheduled an auction of estate personal property, another son, William Staffeldt, filed for emergency injunctive relief, alleging the auction violated the will. The circuit court of Knox County granted a TRO and later a preliminary injunction prohibiting defendants from selling or disposing of any estate property. After multiple continuances, defendants moved to dissolve the injunction in August 2025, arguing the will's 270-day provision authorized the sale, that William had already received all requested property, and that he had an adequate remedy at law. The circuit court denied the motion, and defendants appealed.

The Fourth District Appellate Court affirmed on all issues. The court held that the abuse-of-discretion standard governs review of a denial of a motion to dissolve a preliminary injunction, rejecting defendants' argument that the will-interpretation question warranted de novo review. The court declined to interpret the will in defendants' favor, reasoning that whether the 270-day provision permitted the sale was itself the triable issue the injunction was designed to preserve. The court also found that plaintiff's inability to view estate property in defendants' possession left a genuine factual dispute warranting preservation of the status quo until trial.

For probate and civil litigators, this case reinforces that a motion to dissolve a preliminary injunction faces a high bar on appeal. Arguments attacking the original basis for the injunction — such as adequacy of legal remedies — are largely irrelevant once the court finds no abuse of discretion in denying dissolution. Unresolved access and inventory disputes can independently sustain injunctive relief through trial.

Cory Bliznick filed a declaratory judgment action in Will County circuit court seeking a declaration that he owned a deep well and had the right to connect to it as owner of lot 118. BB Rental Homes, LLC filed a counterclaim seeking an implied easement by prior use with exclusive access to the well. After a bench trial, the circuit court granted Bliznick an easement by necessity, granted BB Rental Homes an implied easement by prior use, denied BB Rental Homes exclusivity, and ordered the parties to enter into a shared well agreement. BB Rental Homes appealed all three rulings.

The Third District affirmed on all issues. First, the court held that Bliznick satisfied the legal tangible interest requirement for a declaratory judgment action because his claim to well ownership or use was a personal claim capable of being affected by declaratory relief — distinguishing the validity of the asserted right (a merits question) from the threshold standing inquiry. Second, the court found BB Rental Homes forfeited its challenge to the shared well agreement order by citing no legal authority, and further noted the order was a proper exercise of the court's inherent power to enforce its own judgment. Third, the court found BB Rental Homes forfeited its exclusivity argument because, despite framing the issue in its statement of issues, its argument section contained no supporting legal authority and failed to actually argue for exclusivity.

This case is a practical reminder that appellate arguments must be fully developed with supporting authority. It also clarifies that the legal tangible interest element for declaratory judgment is a low threshold focused on standing, not the underlying merits.

John Greenfield was injured when a section of culvert pipe fell from Earl Brannan's pickup truck after Brannan purchased the pipe from a Menards store. A Menards employee helped Brannan push the pipe onto his truck, but Brannan alone attempted to secure it before driving away. Greenfield sued Menards under theories of voluntary undertaking and in concert liability. The Circuit Court of Cook County granted summary judgment in favor of Menards, and Greenfield appealed under Illinois Supreme Court Rule 304(a).

The First District Appellate Court affirmed on all grounds. On the voluntary undertaking claim, the court held that Menards' duty was strictly limited to the act actually performed — helping load the pipe — and did not extend to securing the load, a separate and distinct act. The court further held that even if such a duty existed, Brannan's unequivocal testimony that he never expected Menards to secure the pipe independently defeated the reliance element essential to any nonfeasance-based voluntary undertaking claim. On the in concert liability theory under Restatement (Second) of Torts § 876(c), the court found neither substantial assistance — the employee's momentary help lifting the pipe lacked any coordinated plan or active encouragement of Brannan's negligent conduct — nor an independent breach of duty by Menards, as the loading itself was not performed negligently.

For practicing attorneys, this decision reinforces that voluntary undertaking liability is narrowly construed and that retailer assistance with customer loading does not, without more, expose the retailer to liability for the customer's subsequent negligent vehicle operation.

Michael and Vanessa Schenk filed a medical malpractice complaint in Cook County on January 4, 2024, alleging negligent failure to timely diagnose and treat Michael's heart attack at Advocate Condell Medical Center in Libertyville, Lake County. The Schenks reside in Lake County, and all alleged negligence occurred there. Defendants moved to transfer to Lake County under forum non conveniens, but the Cook County circuit court denied the motion, finding defendants failed to show the relevant factors strongly favored transfer. The appellate court granted defendants' Rule 306(a)(2) petition and affirmed.

On appeal, defendants argued the circuit court applied too much deference to plaintiffs' forum choice and misweighed the private and public interest factors. The appellate court held that the circuit court's formulation — that plaintiffs 'don't get as much deference' — was consistent with the 'somewhat less' deference standard applicable to foreign plaintiffs. On the private interest factors, the court emphasized that defendants submitted no affidavits demonstrating hardship, the two physician defendants failed to answer forum non conveniens discovery, and the approximately 40-mile distance between the forums substantially reduced any claimed burden. On the public interest factors, the court found Cook County has some legitimate interest in the litigation because Advocate operates numerous facilities and treats patients in Cook County.

Practically, this decision reinforces that Illinois defendants seeking forum non conveniens transfer must support their motion with concrete affidavit evidence of hardship. Bare assertions of inconvenience, without supporting affidavits, will not satisfy the heavy burden of showing that relevant factors strongly favor transfer, particularly when the two forums are in adjacent counties.

Aaron Krejci filed a replevin action in McHenry County seeking possession of a German Shepherd named Kasha, valued at $4,000, which he claimed he was lawfully entitled to possess. Following a bench trial on September 26, 2025, the trial court found that defendant Kristen Brokaw had a superior possessory interest in the dog and denied plaintiff's request for possession. Plaintiff timely appealed, raising arguments that the trial court erroneously concluded it lacked authority to adjudicate ownership of jointly owned property, refused to consider evidence of his financial ownership interest, and denied him due process.

The Illinois Appellate Court, Second District, affirmed on two independent procedural grounds. First, applying the well-established rule from Foutch v. O'Bryant, the court held that because plaintiff failed to include the bench trial transcript in the record on appeal, it was required to presume the trial court's order was in conformity with the law and had a sufficient factual basis, construing all doubts against the appellant. Second, the court found plaintiff's substantive arguments independently forfeited under Illinois Supreme Court Rule 341(h)(7) because his brief failed to cite the record or provide reasoned legal analysis.

This decision is a straightforward application of foundational Illinois appellate procedure. It serves as a practical reminder that the appellant bears the burden of compiling a complete record and that pro se litigants are held to the same briefing standards as licensed attorneys. Attorneys advising clients on appeal—or reviewing pro se filings—should treat transcript inclusion and Rule 341(h)(7) compliance as threshold requirements.

This opinion from Rule 23 was filed on 2026-07-01. The case "In re A.A" (Docket: AUTO-1056286) addresses important legal issues. Due to technical difficulties, the full AI summary is temporarily unavailable. Please review the full opinion for complete details.

Plaintiff Adam Dane sued defendant Dorile Burnell Sr. alleging that defendant's fence encroached on plaintiff's Rockford, Illinois property, asserting trespass, permanent injunction, and private nuisance claims. Defendant raised adverse possession as a defense. Following a bench trial, the Winnebago County circuit court found that defendant proved adverse possession as to a back-yard chain-link fence but failed to prove adverse possession as to a front-yard split-rail fence (later replaced by a wooden privacy fence). The court entered judgment for plaintiff on the front-yard fence, ordering its removal. Defendant appealed only the adverse finding regarding the split-rail fence.

The sole issue on appeal was whether the circuit court's finding against defendant on the split-rail fence was against the manifest weight of the evidence. The Fourth District affirmed, identifying multiple evidentiary bases supporting the circuit court: a surveyor who performed a 2022 survey of the property saw no split-rail fence and would have depicted one had it existed; photographs appeared to contradict a neighbor's testimony that the new privacy fence stood in the exact same position as the split-rail fence; and defendant himself admitted a fence post had shifted due to ground movement, with additional testimony that defendant had repositioned it.

For practicing attorneys, this decision reinforces that adverse possession claimants bear a heavy burden — all presumptions favor the title owner, and claimants must establish by clear and unequivocal evidence the exact location of the claimed boundary line for the entire 20-year statutory period. Approximation is insufficient, particularly where inches of land are at issue.

In June 2024, the State filed neglect and abuse petitions in Macon County regarding four minor children of Jameira C. (Mother). The minors were adjudicated neglected and made wards of the court. Mother was found dispositionally unfit in July 2024 after failing to appear and remained substantially noncompliant with her service plan over the following year. The State filed a motion to terminate parental rights in July 2025. Following fitness and best interest hearings—at which Mother again failed to appear—the circuit court terminated Mother's parental rights to all four children. Mother appealed, arguing both the unfitness finding and the best interest determination were against the manifest weight of the evidence.

The Fifth District affirmed on both issues. On unfitness, the court found the evidence overwhelming: Mother completed only 1 of 20 required drug screens, attended only 8 of 70 offered visitation sessions, failed to enroll in domestic violence services, and was unsuccessfully discharged from parenting classes. The caseworker testified that the children could not be returned in the reasonably near future. Because proof of a single statutory ground suffices, the court affirmed solely on failure to make reasonable progress and declined to address the remaining grounds.

On best interest, all four minors were thriving in familial placements committed to adoption. One child had cerebral palsy with complex medical needs being fully met by her great-grandparents. The other three were enrolled in therapies and educational programs by their maternal grandmother. Mother had not visited any of the children for months before the final hearing. The court deferred to the circuit court's credibility assessments and affirmed termination.