In re I.D

This Rule 23 order arises from McHenry County juvenile proceedings in which the circuit court adjudicated two minor children neglected, made them wards of the court, and ultimately found respondent father Michael D. an unfit parent before terminating his parental rights. Respondent appealed, and appointed appellate counsel moved to withdraw under Anders v. California, asserting the appeal presented no issue of arguable merit.

The Second District agreed. Reviewing the record, the court found ample evidence supporting the trial court's unfitness finding on multiple statutory grounds, noting that any single ground suffices. The evidence showed respondent failed to engage in recommended services (substance abuse treatment, counseling, drug screens, parenting coaching), failed to maintain contact with his caseworker, and had not visited the children since January 2025—supporting findings of lack of reasonable progress, reasonable interest, and reasonable efforts. At the best-interest stage, respondent presented no evidence, while the State demonstrated the children were thriving in a stable, loving placement with maternal grandparents who had cared for them for nearly two years and intended to adopt. The court also found no arguable challenge to the earlier neglect adjudication (based on stipulations) or to interim permanency orders, since the evidence underlying those rulings was consistent with the termination evidence.

The court granted counsel's motion to withdraw and affirmed the trial court's judgment in full. This decision offers a useful template for applying Anders in termination-of-parental-rights appeals and illustrates the evidentiary showing sufficient to sustain unfitness and best-interest findings under Illinois law.