In re C.P., 145 N.E.3d 605

Respondent (Takiara P.) is a minor mother; her son C.P. was born Nov. 2017 and DCFS was appointed guardian after a neglect petition based on respondent’s mental-health issues.
In April 2018 the trial court adjudicated C.P. neglected, found both parents unfit, and placed custody/guardianship with DCFS.
Respondent was placed at Indian Oaks Academy (IOA) and received therapy, parenting classes, and supervised visits; she had periods of engagement but repeatedly ran away and had incidents of violence.
From Jan.–Apr. 2019 respondent was repeatedly absent/on the run and missed visits and services; DCFS recommended termination.
A fitness hearing (May 2019) resulted in a finding respondent was an unfit parent. A best-interest hearing (June 2019) found termination of respondent’s parental rights was in C.P.’s best interest because C.P. had stability and a strong bond with foster caregiver Erika Campbell.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court lacked jurisdiction to enter the dispositional order because respondent is a minor and her guardian was not served under 705 ILCS 405/2-15	Section 2-15’s reference to "the minor" means the child who is the subject of the proceeding (C.P.), so service to respondent’s guardian was not required	Because respondent is a minor with a guardian, DCFS (as her guardian) was a necessary party and should have been served under §2‑15	Affirmed: "the minor" refers to C.P., not a minor respondent parent; respondent was not shown to be disabled or to have a plenary guardian, so service on her guardian was not required and the court had jurisdiction
Whether termination of respondent’s parental rights was against the manifest weight of the evidence (best-interest determination)	The State: termination is in the child’s best interest because C.P. has stability, continuity, safety, and permanency with his current caregiver	Respondent: she attended visits, bonded with C.P., made parenting progress, and needs more time to address mental-health issues	Affirmed: trial court properly weighed statutory best‑interest factors (security, continuity, least-disruptive placement, safety) and termination was not against the manifest weight of the evidence

In re C.P., 115 N.E.3d 1056 (Ill. App. 4th Dist. 2018) (interpreting "the minor" in §2‑15 as the child who is subject of the proceeding)
In re Jarquan B., 102 N.E.3d 182 (Ill. 2017) (statutory‑interpretation principles; plain‑meaning inquiry)
In re K.C., 753 N.E.2d 314 (Ill. App. 2001) (distinguishing cases where plenary guardians were appointed for disabled adults)
In re Dal. D., 74 N.E.3d 1185 (Ill. App. 4th Dist. 2017) (standard of review and best‑interest factors for termination)
In re D.T., 818 N.E.2d 1214 (Ill. 2004) (parental interest yields to child’s need for stability; burden to prove best interest by preponderance)