In Re Haley D., 959 N.E.2d 1108

Haley D., born to Ralph L. and Patricia D., was exposed to cocaine in utero and placed in protective custody as a neglected minor.
The State filed a petition in Du Page County Juvenile Court alleging Haley as neglected under 705 ILCS 405/2-13 and sought wardship, not termination at that time.
Patricia was served; Ralph was served by abode with his mother at their shared home; both services complied with section 2-15, but Ralph’s attorney later claimed service issues.
After adjudication of neglect, Haley was placed as a ward and a dispositional plan to return her within 12 months was adopted, with DCFS monitoring and ongoing services.
By 2008–2009, Patricia’s involvement waned and Ralph’s progress appeared mixed; the court shifted to a potential change to substitute care pending termination due to concerns.
On February 5, 2009, the State filed a petition to terminate Ralph’s and Patricia’s parental rights under 705 ILCS 405/2-29, but service on Ralph for the termination petition was not properly effectuated and default was entered against him on April 14, 2009.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the April 14 default was properly set aside under 2-1301(e).	Ralph; default should stand given failure to appear.	Ralph; due process requires setting aside for lack of notice and to avoid injustice.	The default should be set aside; 2-1301(e) governs, and substantial justice requires relief.
Did lack of service on Ralph violate due process or jurisdiction for termination proceedings?	People; service on Ralph was improper, undermining due process.	Ralph had prior service in neglect case and appealed; due process requires fair notice, not perfect service.	Lack of notice violated due process; default cannot stand without proper notice and notice compliance.
Whether the April 14 order was a final judgment terminating parental rights?	Termination occurred via later final judgment, not the April 14 finding.	April 14 was a default finding, not a final termination; thus not appealable as final.	April 14 finding was not a final termination; termination occurred later; remand appropriate.

In re Tolbert, 62 Ill. App. 3d 927 (1978) (Adoption/termination context; nonfinality of certain orders)
In re Adoption of D., 317 Ill. App. 3d 155 (2000) (Interlocutory nature of termination order; role of final judgment)
In re E.B., 231 Ill. 2d 459 (2008) (Fundamental liberty interests; best interests framework in termination proceedings)
People v. Vincent, 226 Ill. 2d 1 (2007) (Relief from final orders; meritorious defense and due diligence standards)
In re Marriage of Gutman, 232 Ill. 2d 145 (2008) (Finality and interlocutory considerations in family law)
Sarkissian v. Chicago Board of Education, 201 Ill. 2d 95 (2002) (Pleadings; substance over labeling in relief requests)