In re L.O.

── In re L.O. ── Court: Appellate Court of Illinois Date: June 05, 2026 Category: General 2026 IL App (4th) 260069-U NOTICE FILED This Order was filed under June 5, 2026 Supreme Court Rule 23 and is NO. 4-26-0069 Carla Bender not precedent except in the 4th District Appellate limited circumstances allowed IN THE APPELLATE COURT under Rule 23(e)(1). Court, IL OF ILLINOIS FOURTH DISTRICT In re L.O., a Minor ) Appeal from the ) Circuit Court of (The People of the State of Illinois, ) Peoria County Petitioner-Appellee, ) No. 25JA36 v. ) Lacinda O., ) Honorable Respondent-Appellant). ) David A. Brown, ) Judge Presiding. PRESIDING JUSTICE STEIGMANN delivered the judgment of the court. Justices Lannerd and Cavanagh concurred in the judgment. ORDER ¶1 Held: The appellate court dismissed the appeal for lack of jurisdiction. ¶2 In February 2025, respondent, Lacinda O., gave birth to L.O. Immediately thereafter, the State petitioned to adjudicate L.O. neglected because respondent’s mental health issues made L.O.’s environment injurious to his welfare (see 705 ILCS 405/2-3(1)(b) (2024)). ¶3 Ten months later, at the adjudicatory hearing, the trial court granted L.O.’s father’s motion for a directed finding. (L.O.’s father is not a party to this appeal.) In doing so, the court dismissed the case in its entirety, meaning it dismissed the State’s case against respondent, too, even though it found respondent remained unfit. ¶4 Twenty-nine days later, the State filed a motion to reconsider, and respondent filed a notice of appeal. ¶5 We dismiss this appeal for lack of jurisdiction. ¶6 I. BACKGROUND ¶7 In December 2025, the trial court, orally and in writing, ruled on the State’s petition. In its oral ruling, the court found, as to respondent, the “historical allegations *** ha[d] all been established,” and the State “ha[d] presented credible evidence in support of, basically, all the paragraphs of the petition.” The court noted respondent (1) was found unfit in other termination of parental rights cases; (2) suffered from “a number” of mental health issues, including a bipolar disorder; and (3) could have attained fitness and regained her ability to parent L.O. if she had sought treatment and successfully completed services. However, because she had not, the court determined she remained unfit and her “profound mental health issues *** could definitely negatively impact [L.O.’s] *** well being.” ¶8 The trial court then observed the State did not present any evidence concerning the father’s inability to parent L.O. As a result, it granted the father’s motion for a directed finding and dismissed the case in its entirety. See 735 ILCS 5/2-1110 (West 2024). ¶9 The trial court’s written order provided, “The Court grants Father’s motion for direct finding, and dismisse[s] the State’s petition. The Court finds that [respondent] remains unfit and closes her case. Father has the duty to protect [L.O.] knowing mother remains unfit.” ¶ 10 Given the trial court’s ruling,