In re Tamera W., 2012 IL App (2d) 111131

Tamera W. was born Jan 3, 2008 with cocaine in her system; DCFS took temporary guardianship Feb 28, 2008 and she was placed with maternal grandparents.
Adjudication of neglect occurred May 15, 2008 based on mother’s stipulation; respondent father was later found to be her natural father (June 12, 2008).
Permanency hearings (2008–2010) noted mother’s ongoing issues and respondent’s limited progress; goals shifted toward adoption and continued supervision of visits.
As of Dec 2010, Tamera had significant medical and developmental needs and resided with materal grandparents; respondent’s visits were supervised and limited by circumstances.
April 2011–Sept 2011: unfitness hearing included a stipulation to depravity (count IV) after prior adjudications; best-interest hearing held Sept 15, 2011; respondent testified about his rehabilitation.
October 20, 2011: trial court terminated respondent’s parental rights; this appeal followed challenging admission, conflict, and best-interest determinations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stipulation to unfitness was knowing and voluntary.	State contends admission can be valid; M.H./J.P. do not require Rule 402 admonitions for termination.	Sawley W. argues lack of proper admonitions violated due process.	No reversible error; Rule 402 admonitions not extended to termination proceedings.
Whether a per se conflict of interest existed due to Conflicts II representation.	State relies on prior representation of mother and current representation by same office.	Conflict must be per se and is not shown given separate counsel and lack of knowledge of prior case.	No per se conflict; adequate trial court inquiry showed no involvement with prior case.
Whether termination was against the manifest weight of the evidence for best interests.	Termination supported by evidence of respondent’s inability to meet Tamera’s needs.	respondent argues stability, bond, and relative adoptive option weigh in his favor.	Termination not against manifest weight; best-interest factors support adoption.

In re M.H., 196 Ill. 2d 356 (Ill. 2001) (requires factual basis for admission in unfitness context)
In re J.J., 201 Ill. 2d 236 (Ill. 2002) (due process concerns in parental termination proceedings)
Darius G., 406 Ill. App. 3d 727 (Ill. App. 2010) (per se conflict rule for same attorney representing multiple parties)
In re Paul L.F., 408 Ill. App. 3d 862 (Ill. App. 2011) (reversal where multiple attorneys from same office represented conflicting interests)
People v. Banks, 121 Ill. 2d 36 (Ill. 1987) (public defender office conflicts not automatic disqualification; case-by-case)
People v. Vaughn, 200 Ill. App. 3d 765 (Ill. App. 1990) (two-stage conflict analysis: per se vs actual conflict with prejudice)
Fields, 409 Ill. App. 3d 398 (Ill. App. 2011) (undivided loyalty concept in conflicts within defense)
In re C.W., 199 Ill. 2d 198 (Ill. 2002) (full range of conduct may be considered at best-interests stage)
In re D.L., 191 Ill. 2d 1 (Ill. 2000) (evidence of more recent conduct admissible at best-interest stage)
In re J.P., 316 Ill. App. 3d 652 (Ill. App. 2000) (due process considerations in termination context)
In re Tiffany M., 353 Ill. App. 3d 883 (Ill. App. 2004) (best interests standard applied to termination)