Mother challenge (Illinois) · Go Syfert
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Mother challenge in Illinois

18 Illinois opinions name it 2 courts 1908–2026 8 in the last five years

The cases below were cited by Illinois courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (8)

CaseFollowedCited
In Re DMgreen
illappct · 2002 · cited in 2 Illinois opinions naming this issue, 2025–2025
2 sentences

2025Best Interests ¶ 69 We next turn to the question of whether it was in the best interests of the children to terminate the father’s parental rights. 1 Specifically, the father argues on appeal that the trial court failed to adequately consider his constitutional rights as a parent and the “systemic barriers that 1 The mother does not challenge the trial court’s best interests determination. - 30 - 2025 IL App (2d) 240593-U hindered his ability to bond with his children and demonstrate progress.” He points to the transfer of L.M.’s case from Lake to McHenry County and the court’s finding in June

2025Best Interests ¶ 69 We next turn to the question of whether it was in the best interests of the children to terminate the father’s parental rights. 1 Specifically, the father argues on appeal that the trial court failed to adequately consider his constitutional rights as a parent and the “systemic barriers that 1 The mother does not challenge the trial court’s best interests determination. - 30 - 2025 IL App (2d) 240593-U hindered his ability to bond with his children and demonstrate progress.” He points to the transfer of L.M.’s case from Lake to McHenry County and the court’s finding in June

22
People v. Dorothy H.green
illappct · 2011 · cited in 1 Illinois opinions naming this issue, 2026–2026
1 sentence

2026However, the Mother’s challenge to the court’s disposition order in this case does not involve any of those situations and thus, we reject her argument. ¶ 47 More to the point, this court has addressed this issue at the disposition stage and stated that “issues regarding whether a minor should be adjudged a ward of the court are not related to issues regarding reasonable efforts on the part of DCFS toward reunification.” In re William H., 407 Ill.

11
People v. Colemangreen
ill · 2002 · cited in 1 Illinois opinions naming this issue, 2026–2026
1 sentence

2026People v. Coleman, 206 Ill. 2d 261, 289 (2002). 1 The parents state on appeal that the circuit court denied Mother’s motion to reconsider on February 9, 2026.

11
Witherell v. Weimergreen
ill · 1987 · cited in 1 Illinois opinions naming this issue, 2026–2026
1 sentence

2026Specifically, Mother posits that Mead Johnson’s learned intermediary doctrine argument applies only to her claim of strict liability failure to warn and not to her negligence claim. ¶ 115 The general verdict rule is implicated when the jury renders a general verdict on a case that involves multiple theories of liability or grounds of recovery. “ ‘When there is a general verdict and more than one theory is presented, the verdict will be upheld if there was sufficient evidence to sustain either theory, and the defendant, having failed to request special interrogatories, cannot complain.’ ” Dillo

11
People v. Gail F.green
illappct · 2006 · cited in 1 Illinois opinions naming this issue, 2026–2026
1 sentence

2026In re Gail F., 365 Ill.

11
Dillon v. Evanston Hospitalgreen
ill · 2002 · cited in 1 Illinois opinions naming this issue, 2026–2026
1 sentence

2026Specifically, Mother posits that Mead Johnson’s learned intermediary doctrine argument applies only to her claim of strict liability failure to warn and not to her negligence claim. ¶ 115 The general verdict rule is implicated when the jury renders a general verdict on a case that involves multiple theories of liability or grounds of recovery. “ ‘When there is a general verdict and more than one theory is presented, the verdict will be upheld if there was sufficient evidence to sustain either theory, and the defendant, having failed to request special interrogatories, cannot complain.’ ” Dillo

11
In the Interest of Y.F.green
illappct · 2023 · cited in 1 Illinois opinions naming this issue, 2024–2024
1 sentence

2024See In re Y.F., 2023 IL App (1st) 221216 (limiting review to the fitness findings where the mother did not challenge the court’s finding that it was in the best interest of the minor that the mother’s parental rights be terminated). ¶ 82 For the foregoing reasons, we affirm the trial court’s judgment. ¶ 83 Affirmed. - 22 -

11
People v. Arthur H.green
ill · 2004 · cited in 1 Illinois opinions naming this issue, 2020–2020
1 sentence

2020In re Arthur H., 212 Ill. 2d 441, 462 (2004).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway.

Also cited on this issue (12)

CaseCitedYears
People v. Tracie G. green
illappct · 2010
2 sentences

2019Respondent quotes In re Darius G., 406 Ill.

2018Respondent quotes In re Darius G. , 406 Ill.

22018–2019
In re Parentage of G.E.M. green
illappct · 2008
2 sentences

2010G.E.M., 382 Ill.

2010App.3d 1102 , 322 Ill.Dec. 25 , 890 N.E.2d 944 (2008), the trial court held that a mother could not challenge the paternity of a man with whom she signed a VAP where neither party timely rescinded the VAP and the man did not allege it was signed under fraud, duress, or mistake of fact.

22010–2010
In Re Parentage of GEM green
illappct · 2008
2 sentences

2010App. 3d 1102 , 890 N.E.2d 944 (2008), the trial court held that a mother could not challenge the paternity of a man with whom she signed a VAP where neither party timely rescinded the VAP and the man did not allege it was signed under fraud, duress, or mistake of fact.

2010App.3d 1102 , 322 Ill.Dec. 25 , 890 N.E.2d 944 (2008), the trial court held that a mother could not challenge the paternity of a man with whom she signed a VAP where neither party timely rescinded the VAP and the man did not allege it was signed under fraud, duress, or mistake of fact.

22010–2010
In Re Adoption of Baby Girls Mandell green
illappct · 1991
2 sentences

1993In In re Adoption of Baby Girl Mandell (1991), 213 Ill.App.3d 670 , 157 Ill.Dec. 290 , 572 N.E.2d 359 , it was held that where a mother did not challenge the validity of her consent to adoption within the prescribed 12-month period, she was barred from attempting to establish that the consent was void.

1993App. 3d 670 , 572 N.E.2d 359 , it was held that where a mother did not challenge the validity of her consent to adoption within the prescribed 12-month period, she was barred from attempting to establish that the consent was void.

21993–1993
Salerno v. Innovative Serveillance Technology, Inc. green
illappct · 2010
1 sentence

2026Under a strict liability failure-to-warn theory, “a plaintiff must demonstrate that the manufacturer did not disclose an unreasonably dangerous condition or instruct on the proper use of the product as to which the average consumer would not be aware.” Id. at 499 .

12026–2026
Stolfo v. Kindercare Learning Centers, Inc. green
illappct · 2016
1 sentence

2026Stolfo, 2016 IL App (1st) 142396, ¶ 25 .

12026–2026
In Re D.F. green
ill · 2002
1 sentence

2021D.F., 201 Ill. 2d at 499 . ¶ 65 On appeal, the mother does not challenge the findings of unfitness on grounds b, e, and g.

12021–2021
Filipello v. Filipello green
illappct · 1971
1 sentence

1978Filipello v. Filipello (1971), 130 Ill.

11978–1978
Johnson v. Johnson green
illappct · 1975
1 sentence

1978App. 3d 356, 367 , 340 N.E.2d 68, 77 .) The father’s remarriage and having a larger house than the mother were factors to be considered by the court but were not sufficient reasons for a change of custody.

11978–1978
The PEOPLE v. Nelson neutral
ill · 1969
1 sentence

1970(Cf. People v. Nelson, 42 Ill.2d 172 .) In addition, the testimony of the mother at the hearing on the motion for probation to the effect that she was fighting to keep her son out of the penitentiary demonstrates an awareness that the matter of probation was in doubt.

11970–1970
Welch v. Clark neutral
vt · 1877
1 sentence

1908Appellee contends, however, even if the statements of the prosecutrix be self-serving, that in bastardy proceedings such statements made during pregnancy are admissible in evidehce as tending to corroborate the mother in her claim as to the paternity of the child and cites Robbins v. Smith, 47 Conn. 182 , and Welch v. Clark, 50 Vt. 386 , in support of that claim.

11908–1908
Robbins v. Smith neutral
conn · 1879
1 sentence

1908Appellee contends, however, even if the statements of the prosecutrix be self-serving, that in bastardy proceedings such statements made during pregnancy are admissible in evidehce as tending to corroborate the mother in her claim as to the paternity of the child and cites Robbins v. Smith, 47 Conn. 182 , and Welch v. Clark, 50 Vt. 386 , in support of that claim.

11908–1908

Statutes the citing opinions construe

IL § 705 ILCS 405/2-3 (8) IL § 750 ILCS 50/1 (7) IL § 705 ILCS 405/2-18 (5) IL § 705 ILCS 405/2-29 (5) IL § 705 ILCS 405/1-3 (4) IL § 705 ILCS 405/1-5 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

PA 417 (1995–2026) TX 174 (1993–2026) CA 170 (1929–2026) IN 143 (1995–2026) OH 140 (1993–2026) MO 117 (1993–2025) TN 79 (1998–2026) AZ 72 (2007–2026) UT 61 (2001–2025) NY 60 (1874–2026) IA 55 (2015–2026) NM 35 (1993–2025) OK 32 (1990–2025) WY 30 (2003–2026) FL 29 (1970–2024) AL 29 (1983–2024) NC 28 (1976–2026) SC 19 (1950–2025) IL 18 (1908–2026) MA 17 (2016–2026) MT 17 (1979–2024) KY 16 (1921–2026) HI 16 (2000–2024) ME 14 (2012–2026) OR 12 (1980–2025) GA 11 (1953–2026) VA 11 (2004–2022) ID 10 (2014–2025) WV 9 (1895–2024) KS 8 (2006–2025) MD 7 (1976–2025) DE 7 (2016–2024) DC 6 (1994–2017) AR 5 (1960–2020) SD 5 (1989–2010) WA 4 (2016–2025) VT 3 (2016–2017) CO 2 (2005–2022) NV 2 (2017–2017) WI 2 (1964–2017) NE 2 (1954–1994)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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