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In re Aaron L.
988 N.E.2d 688
Ill. App. Ct.
2013
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Background

  • 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)
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Case Details

Case Name: In re Aaron L.
Court Name: Appellate Court of Illinois
Date Published: Mar 29, 2013
Citation: 988 N.E.2d 688
Docket Number: 1-12-2808
Court Abbreviation: Ill. App. Ct.