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In re A.R. and N.R., Minors

Appellate Court of Illinois · State appellate courts · IL · · 2026 IL App (2d) 250299-U · opinion

Illinois Appellate Court on 2026-03-10 in In re A.R. and N.R., Minors found the self-represented party's appellate brief contained one citation defect involving nonexistent authorities, incorrect statutory or rule text. The court warned the self-represented party to verify legal authorities before future filings.

Disposition
The court warned the self-represented party to verify legal authorities before future filings.
Recorded conduct
The self-represented party's appellate brief contained one citation defect involving nonexistent authorities, incorrect statutory or rule text. — outcome: warning; actor: litigant in person
Canonical record
Incident tracker entry — verified outcome, regulator disposition and related rules

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

after the 150-day deadline. service plans and did not involve a finding of unfitness. ¶ 47 On appeal, respondent, proceeding pro se, argues that: *10 ¶ 50 Further, respondent cites a case, In re K.B., 2019 (1) the trial court's fitness finding was against the manifest IL App (3d) 180086, which does not exist. The citation is weight of the evidence because the State relied on insufficient, therefore erroneous, which could be due to a transcription contradictory, and unreliable testimony; (2) the court erred error (see, e.g., In re K.B., 2019 IL App (4th) 190496) in relying on subjective assertions by CASA and the foster or reliance on an artificial intelligence (AI) research tool. parents that were not based on firsthand knowledge or Although the use of AI is not prohibited, litigants remain observations; (3) the court failed to consider agency-caused responsible for ensuring the accuracy of their filings. In re delays and deficiencies in services; (4) she was denied due Baby Boy, 2025 IL App (4th) 241427, ¶ 131. Citation to process; and (5) the trial court's best interests determination a nonexistent authority is grounds for striking a brief and was against the manifest weight of the evidence. dismissing an appeal. Pletcher v. Village of Libertyville Police Pension Board, 2025 IL App (2d) 240416-U, ¶ 29. Despite ¶ 48 We first address the State's argument that respondent's respondent's failure to comply with Rule 341(h) and her statement of facts should be stricken and her arguments erroneous citations, we will address her arguments on the deemed forfeited for failure to comply with Illinois Supreme merits because a biological parent's right to raise his or her Court Rule 341(h) (eff. Oct. 1, 2020). Rule 341(h) governs child is a fundamental liberty interest, and the involuntary the contents and requirements of an appellant's brief. Rule termination of parental rights is a drastic measure (In re 341(h)(6) provides that the statement of facts “shall contain Gwynne P., 215 Ill. 2d 340, 353 (2005)). In re C.R., 2024 the facts necessary to an understanding of the case, stated IL App (4th) 231441-U, ¶ 20 (addressing termination on the

Authorities cited in the passage: s brief cited a non-existent authority · Pletcher v. Village of Libertyville Police Pension Board

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