In re N.R.

── In re N.R. ── Court: Appellate Court of Illinois Date: April 14, 2026 Category: General 2026 IL App (2d) 250575-U Nos. 2-25-0575, 2-25-0576, 2-25-0577, 2-25-0581, & 2-25-0582 cons. Order filed April 13, 2026 NOTICE: This order was filed under Supreme Court Rule 23(b) and is not precedent except in the limited circumstances allowed under Rule 23(e)(1). IN THE APPELLATE COURT OF ILLINOIS SECOND DISTRICT In re N.R., a Minor. (The People of the State of Illinois, Petitioner-Appellee v. Yoni R., Respondent-Appellant.) Appeal from the Circuit Court of Kane County. Honorable Kathryn D. Karayannis, Judge, Presiding. No. 22-JA-148. In re E.R., a Minor. (The People of the State of Illinois, Petitioner-Appellee v. Yoni R., Respondent-Appellant.) Appeal from the Circuit Court of Kane County. Honorable Kathryn D. Karayannis, Judge, Presiding. No. 22-JA-150. In re Y.R., a Minor. (The People of the State of Illinois, Petitioner-Appellee v. Yoni R., Respondent-Appellant.) Appeal from the Circuit Court of Kane County. Honorable Kathryn D. Karayannis, Judge, Presiding. No. 22-JA-151.  In re I.R., a Minor. (The People of the State of Illinois, Petitioner-Appellee v. Yoni R., Respondent-Appellant.) Appeal from the Circuit Court of Kane County. Honorable Kathryn D. Karayannis, Judge, Presiding. No. 22-JA-152. In re ELIAS R., a Minor. (The People of the State of Illinois, Petitioner-Appellee v. Yoni R., Respondent-Appellant.) Appeal from the Circuit Court of Kane County. Honorable Kathryn D. Karayannis, Judge, Presiding. No. 22-JA-153. JUSTICE SCHOSTOK delivered the judgment of the court. Presiding Justice Kennedy and Justice Jorgensen concurred in the judgment. ORDER ¶1 Held: While the trial court erred in its application of the law-of-the-case doctrine, the trial court did not abuse its discretion by denying respondent’s request for a stay. ¶2 Respondent, Yoni R., appeals from the trial court’s order striking his motion to stay the best interests hearing in proceedings to terminate his parental rights. For the reasons that follow, we affirm. ¶3 I. BACKGROUND ¶4 As the record in this case is voluminous, we recite only those facts necessary to the resolution of this appeal. ¶5 Respondent and Carolina F. were the biological parents to five minor children: N.R., E.R., I.R., Y.R., and E.R. On December 22, 2022, the State filed petitions for adjudication in the trial court alleging that each of the five children was neglected based on their parents’ history of -2- domestic violence. That same day, the State obtained a temporary order placing the children in the custody of the Department of Children and Family Services (DCFS). The trial court also appointed a guardian ad litem (GAL) for the children. ¶6 On February 10, 2023, respondent and Carolina stipulated to the factual basis of the State’s petition. On March 10, 2023, the trial court adjudicated the children neglected under section 2- 3(1)(b) of the Juvenile Court Act of 1987 (705 ILCS 405/2-3(1)(