In re Aaron L.
988 N.E.2d 688
Ill. App. Ct.2013Background
- Aaron L., born May 12, 1993, was adjudged neglected and placed in DCFS guardianship as a ward in 1994.
- He lived in foster homes; DCFS was found to have failed to achieve permanency goals at various times.
- Hattie D. served as guardian from 1999 to 2006; post-guardianship, Aaron again became a DCFS ward and fostered.
- Aaron faced behavioral and substance issues; a 2007 psych report noted severe behavioral problems and low cognitive functioning.
- From 2010 onward Aaron progressed through residential settings and a transitional living program (TLP) aimed at independence.
- In March 2012, the GAL sought an extension to age 21; the court granted a six-month extension; by August 2012, concerns about compliance and stability rose.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the court comply with 2-31(2) when terminating wardship? | Public Guardian argues failure to make written findings about best interests and independence. | Aaron contends court could terminate based on factors showing readiness. | No; court failed to make required written findings and consider best interests. |
| Was the wardship termination and case closure supported by the weight of the evidence? | Record shows Aaron lacked independence, employment, and stability to live on his own. | Court believed services were ineffective and that closure served Aaron's interests. | No; the evidence supported continuing wardship to ensure readiness for independence. |
Key Cases Cited
- In re Vicente G., 408 Ill. App. 3d 679 (2011) (failure to provide required 2-31(2) findings invalidates closure)
- In re Aaron R., 387 Ill. App. 3d 1130 (2009) (sufficiency of evidence to support wardship/guardianship termination)
- In re Shawn B., 218 Ill. App. 3d 374 (1991) (best interest and independence considerations in guardianship termination)
