in-person hearing in Illinois

2022Id. ¶ 153 On appeal, the respondent claimed that the trial court denied him his right to an in-person hearing and violated his due process right to appear personally at all stages of the proceedings.

2021Id. ¶ 154 On appeal, the respondent claimed that the trial court denied him his right to an in-person hearing and violated his due process right to appear personally at all stages of the proceedings.

2024Id. at 805 ; see also In re C.J., 272 Ill.

2021As Rule 137(a) provides, “[t]he signature of an attorney *** constitutes a certificate by him that he has read the *** motion *** [and] that to the best of his knowledge, information, and belief formed after reasonable inquiry it is well grounded in fact and is warranted by existing law.” Id. ¶ 114 Under these circumstances—where the trial court had held in-person hearings in this case throughout the COVID-19 pandemic, including an in-person hearing just weeks before the hearing at issue, and where there was a misunderstanding of the State’s intentions with respect to Father’s planned request

2022Maryland v. Craig, 497 U.S. 836, 851 (1990); see R.D., 2021 IL App (1st) 201411, ¶ 15 (noting - 17 - 2022 IL App (2d) 210404 in-person testimony and cross-examination are preferred over remote testimony); People v. Lofton, 194 Ill. 2d 40, 56 (2000) (citing Craig and noting preference for in-person confrontation); see also Ill.

2021R.D., 2021 IL App (1st) 201411, ¶ 30 ; see also P.S., 2021 IL App (5th) 210027, ¶ 63 (also finding the circuit court did not abuse its discretion in denying a motion for a continuance of termination proceedings during the COVID-19 pandemic until an in-person hearing could be held); R.L., 2021 IL App (1st) 210419, ¶ 17 (same).

2022Maryland v. Craig, 497 U.S. 836, 851 (1990); see R.D., 2021 IL App (1st) 201411, ¶ 15 (noting - 17 - 2022 IL App (2d) 210404 in-person testimony and cross-examination are preferred over remote testimony); People v. Lofton, 194 Ill. 2d 40, 56 (2000) (citing Craig and noting preference for in-person confrontation); see also Ill.

2022Maryland v. Craig, 497 U.S. 836, 851 (1990); see R.D., 2021 IL App (1st) 201411, ¶ 15 (noting - 17 - 2022 IL App (2d) 210404 in-person testimony and cross-examination are preferred over remote testimony); People v. Lofton, 194 Ill. 2d 40, 56 (2000) (citing Craig and noting preference for in-person confrontation); see also Ill.

2022Maryland v. Craig, 497 U.S. 836, 851 (1990); see R.D., 2021 IL App (1st) 201411, ¶ 15 (noting - 17 - 2022 IL App (2d) 210404 in-person testimony and cross-examination are preferred over remote testimony); People v. Lofton, 194 Ill. 2d 40, 56 (2000) (citing Craig and noting preference for in-person confrontation); see also Ill.

2021See J.M., 2020 IL App (2d) 190806, ¶ 49 (considering the “lengthy delay in the proceedings” that would have been necessary to arrange for the incarcerated father to be transported from a Wisconsin prison to Illinois for a hearing); M.R., 316 Ill.

2021R.D., 2021 IL App (1st) 201411, ¶ 30 ; see also P.S., 2021 IL App (5th) 210027, ¶ 63 (also finding the circuit court did not abuse its discretion in denying a motion for a continuance of termination proceedings during the COVID-19 pandemic until an in-person hearing could be held); R.L., 2021 IL App (1st) 210419, ¶ 17 (same).

2021See J.M., 2020 IL App (2d) 190806, ¶ 49 (considering the “lengthy delay in the proceedings” that would have been necessary to arrange for the incarcerated father to be transported from a Wisconsin prison to Illinois for a hearing); M.R., 316 Ill.

2021They also contend that during Zoom hearings the trial court could not effectively assess the credibility of witnesses because “it is impossible to monitor whether one or more unauthorized individuals were outside the view of the audio-video camera affecting witness testimony.” ¶ 19 Fundamentally, procedural due process requires an opportunity to be heard “at a meaningful time and in a meaningful manner.” (Internal quotation marks omitted.) Mathews v. Eldridge, 424 U.S. 319, 333 (1976).