{
  "id": 1025899,
  "name": "In re J.D. (Jane Doe, Plaintiff-Appellant, v. John Noe et al., Defendants-Appellees)",
  "name_abbreviation": "Doe v. Noe",
  "decision_date": "2000-11-21",
  "docket_number": "No. 4-00-0001",
  "first_page": "419",
  "last_page": "428",
  "citations": [
    {
      "type": "official",
      "cite": "317 Ill. App. 3d 419"
    }
  ],
  "court": {
    "name_abbreviation": "Ill. App. Ct.",
    "id": 8837,
    "name": "Illinois Appellate Court"
  },
  "jurisdiction": {
    "id": 29,
    "name_long": "Illinois",
    "name": "Ill."
  },
  "cites_to": [
    {
      "cite": "418 N.E.2d 751",
      "category": "reporters:state_regional",
      "reporter": "N.E.2d",
      "weight": 2,
      "year": 1981,
      "pin_cites": [
        {
          "page": "754"
        },
        {
          "page": "755"
        }
      ],
      "opinion_index": 0
    },
    {
      "cite": "84 Ill. 2d 323",
      "category": "reporters:state",
      "reporter": "Ill. 2d",
      "case_ids": [
        3045800
      ],
      "weight": 2,
      "year": 1981,
      "pin_cites": [
        {
          "page": "329"
        },
        {
          "page": "332"
        }
      ],
      "opinion_index": 0,
      "case_paths": [
        "/ill-2d/84/0323-01"
      ]
    },
    {
      "cite": "572 N.E.2d 359",
      "category": "reporters:state_regional",
      "reporter": "N.E.2d",
      "year": 1991,
      "pin_cites": [
        {
          "page": "361"
        }
      ],
      "opinion_index": 0
    },
    {
      "cite": "213 Ill. App. 3d 670",
      "category": "reporters:state",
      "reporter": "Ill. App. 3d",
      "case_ids": [
        2604481
      ],
      "year": 1991,
      "pin_cites": [
        {
          "page": "674"
        }
      ],
      "opinion_index": 0,
      "case_paths": [
        "/ill-app-3d/213/0670-01"
      ]
    },
    {
      "cite": "491 N.E.2d 29",
      "category": "reporters:state_regional",
      "reporter": "N.E.2d",
      "year": 1986,
      "pin_cites": [
        {
          "page": "32"
        }
      ],
      "opinion_index": 0
    },
    {
      "cite": "141 Ill. App. 3d 871",
      "category": "reporters:state",
      "reporter": "Ill. App. 3d",
      "case_ids": [
        3496292
      ],
      "year": 1986,
      "pin_cites": [
        {
          "page": "876"
        }
      ],
      "opinion_index": 0,
      "case_paths": [
        "/ill-app-3d/141/0871-01"
      ]
    },
    {
      "cite": "79 N.E. 695",
      "category": "reporters:state_regional",
      "reporter": "N.E.",
      "year": 1906,
      "pin_cites": [
        {
          "page": "697"
        }
      ],
      "opinion_index": 0
    },
    {
      "cite": "224 Ill. 468",
      "category": "reporters:state",
      "reporter": "Ill.",
      "case_ids": [
        3333561
      ],
      "year": 1906,
      "pin_cites": [
        {
          "page": "476"
        }
      ],
      "opinion_index": 0,
      "case_paths": [
        "/ill/224/0468-01"
      ]
    },
    {
      "cite": "664 N.E.2d 347",
      "category": "reporters:state_regional",
      "reporter": "N.E.2d",
      "year": 1996,
      "pin_cites": [
        {
          "page": "348-49"
        }
      ],
      "opinion_index": 0
    },
    {
      "cite": "278 Ill. App. 3d 1091",
      "category": "reporters:state",
      "reporter": "Ill. App. 3d",
      "case_ids": [
        1156821
      ],
      "year": 1996,
      "pin_cites": [
        {
          "page": "1093-94"
        }
      ],
      "opinion_index": 0,
      "case_paths": [
        "/ill-app-3d/278/1091-01"
      ]
    },
    {
      "cite": "630 N.E.2d 1180",
      "category": "reporters:state_regional",
      "reporter": "N.E.2d",
      "weight": 6,
      "year": 1994,
      "pin_cites": [
        {
          "page": "1189-90",
          "parenthetical": "holding that a final and irrevocable consent to adoption was limited by an express intent to apply only to a specific prospective adoptive parent even though no adoption petition was pending"
        },
        {
          "page": "1190"
        },
        {
          "page": "1187"
        },
        {
          "page": "1188"
        },
        {
          "page": "1182, 1184"
        },
        {
          "page": "1196",
          "parenthetical": "a finding of equitable estoppel against a public body is disfavored"
        }
      ],
      "opinion_index": 0
    },
    {
      "cite": "258 Ill. App. 3d 954",
      "category": "reporters:state",
      "reporter": "Ill. App. 3d",
      "case_ids": [
        2883241
      ],
      "weight": 6,
      "year": 1994,
      "pin_cites": [
        {
          "page": "967-68",
          "parenthetical": "holding that a final and irrevocable consent to adoption was limited by an express intent to apply only to a specific prospective adoptive parent even though no adoption petition was pending"
        },
        {
          "page": "967-68"
        },
        {
          "page": "964"
        },
        {
          "page": "965"
        },
        {
          "page": "956, 960"
        },
        {
          "page": "977-78"
        }
      ],
      "opinion_index": 0,
      "case_paths": [
        "/ill-app-3d/258/0954-01"
      ]
    },
    {
      "cite": "77 N.E.2d 187",
      "category": "reporters:state_regional",
      "reporter": "N.E.2d",
      "year": 1948,
      "pin_cites": [
        {
          "page": "189"
        }
      ],
      "opinion_index": 0
    },
    {
      "cite": "399 Ill. 196",
      "category": "reporters:state",
      "reporter": "Ill.",
      "case_ids": [
        2460720
      ],
      "year": 1948,
      "pin_cites": [
        {
          "page": "199"
        }
      ],
      "opinion_index": 0,
      "case_paths": [
        "/ill/399/0196-01"
      ]
    },
    {
      "cite": "230 N.E.2d 865",
      "category": "reporters:state_regional",
      "reporter": "N.E.2d",
      "weight": 2,
      "year": 1967,
      "pin_cites": [
        {
          "page": "867"
        },
        {
          "page": "867"
        }
      ],
      "opinion_index": 0
    },
    {
      "cite": "38 Ill. 2d 289",
      "category": "reporters:state",
      "reporter": "Ill. 2d",
      "case_ids": [
        2859851
      ],
      "weight": 2,
      "year": 1967,
      "pin_cites": [
        {
          "page": "291"
        },
        {
          "page": "292-93"
        }
      ],
      "opinion_index": 0,
      "case_paths": [
        "/ill-2d/38/0289-01"
      ]
    },
    {
      "cite": "152 N.E. 554",
      "category": "reporters:state_regional",
      "reporter": "N.E.",
      "year": 1926,
      "pin_cites": [
        {
          "page": "554"
        }
      ],
      "opinion_index": 0
    },
    {
      "cite": "322 Ill. 95",
      "category": "reporters:state",
      "reporter": "Ill.",
      "case_ids": [
        5173726
      ],
      "year": 1926,
      "pin_cites": [
        {
          "page": "96"
        }
      ],
      "opinion_index": 0,
      "case_paths": [
        "/ill/322/0095-01"
      ]
    }
  ],
  "analysis": {
    "cardinality": 850,
    "char_count": 19892,
    "ocr_confidence": 0.772,
    "pagerank": {
      "raw": 1.0655841273531072e-07,
      "percentile": 0.5582792664746091
    },
    "sha256": "96b4462594177340725320c31ac3e6f61284cb11f11faaaba3cbbf6b736012ab",
    "simhash": "1:1abfed74ec1bdf43",
    "word_count": 3368
  },
  "last_updated": "2023-07-14T15:16:30.528913+00:00",
  "provenance": {
    "date_added": "2019-08-29",
    "source": "Harvard",
    "batch": "2018"
  },
  "casebody": {
    "judges": [],
    "parties": [
      "In re J.D. (Jane Doe, Plaintiff-Appellant, v. John Noe et al., Defendants-Appellees)."
    ],
    "opinions": [
      {
        "text": "JUSTICE STEIGMANN\ndelivered the opinion of the court:\nIn June 1999, plaintiff, referred to herein as Jane Doe, filed a ha-beas corpus petition herein to void the trial court\u2019s June 1998 judgment granting adoption of her sister\u2019s minor child, referred to herein as J.D., to defendants, referred to herein as the Noes, in McLean County case No. 98 \u2014 AD\u201410. In December 1999, the trial court dismissed Jane\u2019s petition. Jane appeals, arguing that (1) the adoption order is void for lack of jurisdiction; and (2) she has standing to chai-lenge the adoption because she is a third-party beneficiary of an alleged oral agreement between her sister (referred to herein as Joyce Doe) and the Department of Children and Family Services (DCFS), providing that she would be allowed to adopt J.D. We affirm.\nI. BACKGROUND\nWhen J.D. was born in August 1993, he tested positive for cannabis and cocaine. Two days later, DCFS took him into protective custody and temporarily placed him in Jane\u2019s care. In September 1993, the trial court adjudicated J.D. a neglected minor; and in October 1993, DCFS became his guardian. Jane retained custody.\nIn January 1996, Joyce signed a final and irrevocable surrender of her parental rights as to J.D. and acknowledged her surrender before a juvenile court judge. In April 1996, the State filed a petition to terminate Joyce\u2019s parental rights. In July 1996, the trial court terminated Joyce\u2019s parental rights and gave DCFS the authority to consent to J.D.\u2019s adoption. Although J.D. was then in Jane\u2019s care, she did not file any petition to adopt him.\nIn January 1997, DCFS removed J.D. from Jane\u2019s care because he had bruises consistent with those received from a spanking. DCFS determined that the abuse report was indicated and placed J.D. with other foster parents. In August 1997, the trial court found that the permanency goal of adoption had not been achieved and that it was in J.D.\u2019s best interests to be placed immediately in an adoptive home. The court also terminated Jane\u2019s visitation with J.D.\nIn December 1997, the Baby Fold, a private agency, placed J.D. with John and Jill Noe. In February 1998, the Noes filed a petition to adopt J.D. Jane and her counsel learned of the pending adoption petition when they attended an unrelated March 1998 hearing and counsel for DCFS informed the court about J.D.\u2019s adoptive status. However, Jane never filed a petition to adopt J.D., nor did she seek to intervene in the adoption proceeding. In May 1998, DCFS provided its written consent to J.D.\u2019s adoption by the Noes. In June 1998, the Noes obtained an adoption judgment.\nJane urges us to consider several additional alleged facts: (1) she administratively appealed J.D.\u2019s removal and the indicated abuse report, but she never received a \u201cfair hearing\u201d as required by DCFS regulations (89 Ill. Adm. Code \u00a7 337.120 (1996) (effective July 1, 1995)); (2) DCFS did not follow its policy and custom of staying all actions regarding a child pending a foster parent\u2019s administrative appeal; (3) she was not notified of any proceedings in the juvenile court that terminated her visitation rights; (4) DCFS refused to return J.D. to her care unless she admitted spanking him; (5) a juvenile court judge asked counsel for DCFS to seek advice from DCFS\u2019 regional counsel about how to expedite or \u201cget around\u201d Jane\u2019s administrative appeal; and (6) in December 1998, DCFS voluntarily \u201cunfounded\u201d the indicated report of abuse involving Jane and J.D. However, these allegations are not relevant to any of the dispositive issues in this appeal.\nIn June 1999, Jane filed the instant habeas corpus petition alleging that J.D. was \u201cimprisoned\u201d in the Noes\u2019 home. She argued that J.D.\u2019s adoption was invalid because Joyce\u2019s surrender of her parental rights was subject to an oral agreement with DCFS to allow Jane to adopt J.D. The trial court dismissed the petition because Jane did not have standing to seek J.D.\u2019s custody and could not collaterally attack the adoption judgment. This appeal followed.\nII. ANALYSIS\nA. Jurisdiction\nJane characterizes the adoption judgment as void for lack of jurisdiction. She argues that the trial court did not have jurisdiction because J.D. was not \u201cavailable for adoption\u201d as defined by section 1(F) of the Adoption Act (750 ILCS 50/l(F) (West 1998)). We disagree.\nA child is available for adoption if the child has been surrendered for adoption to an agency and the agency has thereafter consented. 750 ILCS 50/1 (F) (a) (West 1998). The trial court may enter an adoption judgment if it finds that (1) the adoption is for the welfare of the child and (2) either a valid consent exists or no consent is required. 750 ILCS 50/14(e) (West 1998). An agency may make a valid consent if the child has been surrendered for adoption to such agency. 750 ILCS 50/8(b)(3) (West 1998).\nA valid adoption is a complete defense to a petition for habeas corpus. People ex rel. O\u2019Connor v. Cole, 322 Ill. 95, 96, 152 N.E. 554, 554 (1926). While habeas corpus is an appropriate means to collaterally attack an adoption order where that order is void for want of jurisdiction (Greco v. Chicago Foundlings Home, 38 Ill. 2d 289, 291, 230 N.E.2d 865, 867 (1967)), the scope of inquiry in such a proceeding is limited to determining whether the trial court possessed jurisdiction (Gebhardt v. Warren, 399 Ill. 196, 199, 77 N.E.2d 187, 189 (1948)). Prior to invoking habeas corpus relief, a petitioner must show a prima facie legal right to custody of the child. Greco, 38 Ill. 2d at 292-93, 230 N.E.2d at 867.\nIn this case, J.D.\u2019s biological mother, Joyce, voluntarily surrendered her parental rights to J.D. by executing, under section 10(C) of the Adoption Act (750 ILCS 50/10(C) (West 1998)), a final and irrevocable surrender to an agency for purposes of adoption. The form of that surrender complied with the requirements of section 10(C) of the Adoption Act, and Joyce acknowledged her surrender before a judge (see 750 ILCS 50/10(1) (West 1998)).\nJ.D. was available for adoption because Joyce surrendered J.D. to DCFS for purposes of adoption and DCFS consented to J.D.\u2019s adoption by the Noes. Therefore, the adoption court had jurisdiction to enter an adoption judgment.\nB. Standing\nJane argues that she has standing as a third-party beneficiary to specifically enforce the terms of an alleged oral contract of adoption between DCFS and Joyce. Jane maintains that Joyce executed a general surrender of her parental rights in exchange for DCFS\u2019 promise to consent to J.D.\u2019s adoption by Jane. As a result, Jane claims that she was vested with DCFS\u2019 consent to adopt J.D. by operation of law, even though DCFS did not execute a consent in her favor. Thus, she contends that she does not need to void or revoke Joyce\u2019s surrender to attack the adoption judgment. We disagree.\nDCFS gained the power to consent to J.D.\u2019s adoption by the Noes based on Joyce\u2019s surrender of her parental rights. See 750 ILCS 50/ 8(b)(3) (West 1998). Her surrender provided:\n\u201cThat I hereby grant to [DCFS] *** full power and authority to place such child with any person or persons it may in its sole discretion select to become the adopting parent or parents and to consent to the legal adoption of such child by such person or persons ***.\u201d\nSee 750 ILCS 50/10(0 (West 1998).\nJane argues that Joyce\u2019s unequivocal surrender is limited by an alleged oral agreement that DCFS consent to J.D.\u2019s adoption by Jane. Her argument is akin to one previously used by a natural parent seeking to revoke a consent in In re Joseph B., 258 Ill. App. 3d 954, 967-68, 630 N.E.2d 1180, 1189-90 (1994) (holding that a final and irrevocable consent to adoption was limited by an express intent to apply only to a specific prospective adoptive parent even though no adoption petition was pending). In Joseph B., the natural mother expressly stated during the hearing at which the consent was elicited that she would voluntarily sign the consent \u201cas long as [J.B.\u2019s] placement is with [Z.S.]\u201d Joseph B., 258 Ill. App. 3d at 967-68, 630 N.E.2d at 1190.\nHowever, Joseph B. is distinguishable. Joyce signed a \u201cfinal and irrevocable surrender to an agency for purposes of adoption\u201d (see 750 ILCS 50/10(C) (West 1996) (effective until January 1, 1998)) as opposed to a \u201cfinal and irrevocable consent to adoption\u201d (750 ILCS 50/ 10(A) (West 1996) (effective until January 1, 1998)). These forms are not interchangeable. Joseph B., 258 Ill. App. 3d at 964, 630 N.E.2d at 1187. The language granting an agency power \u201cto place such child for adoption and to consent to the legal adoption of such child\u201d (750 ILCS 50/10(0 (West 1996) (effective until January 1, 1998)) is not contained in the consent form. Joseph B., 258 Ill. App. 3d at 965, 630 N.E.2d at 1188.\nFurther, Joyce had no power to execute a consent. J.D. was a ward of the court when Joyce signed the surrender. In Joseph B., the child was not a ward of the court at the time that the natural parent signed a consent to adoption. Joseph B., 258 Ill. App. 3d at 956, 960, 630 N.E.2d at 1182, 1184. A parent may not direct a child\u2019s placement either through private placement or by executing a consent when that child is a ward of the court. In re Adoption of L.R.B., 278 Ill. App. 3d 1091, 1093-94, 664 N.E.2d 347, 348-49 (1996).\nJane maintains that Joyce intended her to adopt J.D., and she asserts that DCFS agreed to consent to that adoption. However, the record shows no evidence to support that entire claim. She has not provided a transcript of the hearing at which Joyce surrendered her parental rights, and Joyce did not testify in the pr\u00e9sent proceeding. Instead, Jane refers to a June 1996 DCFS \u201cclient service plan narrative\u201d that mentioned, \u201c[Joyce], the natural mother, has surrendered her parental rights so that her sister, [Jane], may proceed with [J.D.\u2019s] adoption.\u201d Although this statement suggests Joyce\u2019s expectation, it does not condition her surrender or in any way indicate that DCFS agreed to consent to J.D.\u2019s adoption by Jane. Also, Jane refers to Joyce\u2019s parental affidavit which contains the question, \u201cHas anyone threatened or made promises to you to encourage the surrender of the child?\u201d Jane alleges that someone other than Joyce crossed out her \u201cyes\u201d response and noted the change with Joyce\u2019s initials. However, Jane has not supported her allegation with a transcript of the proceeding in which Joyce acknowledged her surrender in open court. In any case, nothing in this statement necessarily indicates that DCFS made any promises to Joyce.\nEven if DCFS agreed to consent to Jane\u2019s adoption of J.D., that agreement would not prevent DCFS from also consenting to J.D.\u2019s adoption by the Noes. Under these circumstances, we refuse to apply equitable estoppel to bar DCFS from consenting to J.D.\u2019s adoption by anyone other than Jane. See Joseph B., 258 Ill. App. 3d at 977-78, 630 N.E.2d at 1196 (a finding of equitable estoppel against a public body is disfavored). Jane had sufficient opportunity to file a petition to adopt J.D. before the Noes obtained an adoption judgment. She had actual notice of the pending adoption proceedings. In March 1998, Jane learned in open court of a pending petition to adopt J.D. However, she never filed a petition to adopt J.D., and she never sought to intervene in the pending adoption proceeding. She claims that two indicated reports against her and her pending administrative appeals of those reports precluded her from filing a petition to adopt J.D. We disagree. Jane could have filed a petition to adopt J.D. at any time before the Noes obtained their adoption judgment because J.D. was then a \u201crelated child\u201d as defined in section 1(B) of the Adoption Act (750 ILCS 50/ 1(B) (West Supp. 1997)). Accordingly, she would not have needed to allege in her petition that she had custody of J.D. or that DCFS consented. See 750 ILCS 50/5(C) (West 1998).\nThus, Jane cannot attack the adoption judgment without seeking to void or revoke Joyce\u2019s surrender. However, she does not have standing to do so. When contesting the validity of adoption proceedings, \u201cno other person can complain that the rights of the father or mother have been infringed.\u201d Sullivan v. People ex rel. Heeney, 224 Ill. 468, 476, 79 N.E. 695, 697 (1906). Nothing in section 11 of the Adoption Act explicitly provides standing to void or revoke a surrender signed by someone else. See 750 ILCS 50/11 (West 1998).\nC. Twelve-Month Limitation\nJane\u2019s challenge to the trial court\u2019s jurisdiction is also time-barred. Section 11(a) of the Adoption Act provides, in relevant part:\n\u201cNo action to void or revoke a consent to or surrender for adoption, including an action based on fraud or duress, may be commenced after 12 months from the date the consent or surrender was executed.\u201d 750 ILCS 50/ll(a) (West 1998).\nJane cannot seek to enforce an oral contract for adoption or, alternatively, seek to set aside an adoption judgment after the time for challenging the surrender has passed. See Street v. Hubert, 141 Ill. App. 3d 871, 876, 491 N.E.2d 29, 32 (1986). Any jurisdictional challenge to the validity of an adoption judgment, regardless of the means utilized, is time-barred when premised on a challenge to the validity of a consent or surrender more than 12 months after it was executed. In re Adoption of Baby Girls Mandell, 213 Ill. App. 3d 670, 674, 572 N.E.2d 359, 361 (1991).\nIn this case, Jane\u2019s attack on the adoption judgment constitutes a challenge to the validity of the surrender. Because Jane filed her ha-beas corpus petition in June 1999, 3V2 years after Joyce executed the surrender, section 11 of the Adoption Act (750 ILCS 50/11 (West 1998)) bars her claim.\nD. Other Grounds\nWe recognize that DCFS has also argued in favor of affirming the trial court on the following grounds: (1) Jane cannot assert that Joyce\u2019s surrender was induced by fraud because she did not allege in the complaint that the judge before whom Joyce acknowledged her surrender perpetrated the fraud; (2) Joyce could not bypass the authority of the courts and DCFS, J.D.\u2019s guardian, to select an adoptive placement for J.D., a ward of the court; (3) Jane had no standing under section 601(b)(2) of the Illinois Marriage and Dissolution of Marriage Act (750 ILCS 5/601(b)(2) (West 1998)) to seek custody of J.D. after the adoption judgment because J.D. was then in the custody of the Noes, his adoptive parents; (4) DCFS did not enter into a \u201ccontract for adoption\u201d with Joyce because it had no authority to do so; (5) Jane had no constitutional right as a former foster parent to have J.D. returned to her; and (6) nothing that DCFS or the court did or failed to do undermined the validity of the adoption judgment. Although these arguments have merit, we need not address them because the grounds that we have considered are sufficient to affirm the trial court\u2019s judgment.\nIII. CONFIDENTIALITY IN ADOPTION-RELATED PROCEEDINGS\nBecause this petition was filed in the adoption proceeding, we choose to use pseudonyms in accordance with section 18(d) of the Adoption Act (750 ILCS 50/18(d) (West 1998)). Section 18 of the Adoption Act provides in part as follows:\n\u201cRecords confidential. ***\n(b) The court call of adoption proceedings shall not identify any of the parties by name. The parties may be identified by initials or pseudonyms. The case shall be identified by its general number. The names of the lawyers representing the parties may appear on the court call, and the type of application that is being made to the court may also be identified.\n(c) All adoption records maintained by each circuit clerk shall be impounded in accordance with the procedures provided by the Illinois Supreme Court\u2019s General Administrative Order on Record-keeping and shall be opened for examination only upon specific order of the court, which order shall name the person or persons who are to be permitted to examine the file. Certified copies of all papers and documents contained in any file so impounded shall be made only on like order. The guardian ad litem for a minor sought to be adopted shall have the right to inspect the court file without leave of court during the pendency of the proceeding. The attorney of record for the petitioners and other parties may inspect the file only with leave of court. The petitioners to the adoption, the attorney of record for the petitioners, and the guardian ad litem of the person who is the subject of the proceeding shall be entitled to receive certified copies of the order of adoption in the proceeding at any time within 30 days after the entry of the judgment of adoption without order of court. After 30 days from the entry of the judgment of adoption, no copies may be obtained without prior order of court, but good cause is not necessary to be shown by one of the petitioners to the adoption.\n(d) If an appeal is taken from an adoption proceeding, the papers filed in the court of review and the opinion of the reviewing court shall not identify the true names of the parties; instead, initials or pseudonyms shall be used to identify the parties.\u201d 750 ILCS 50/18 (West 1998).\nSection 18 of the Adoption Act represents a considered legislative judgment that confidentiality promotes the integrity of the adoption process. In re Roger B., 84 Ill. 2d 323, 329, 418 N.E.2d 751, 754 (1981). Confidentiality protects the interests of biological parents, adopting parents, and adopted minors. Roger B., 84 Ill. 2d at 332, 418 N.E.2d at 755.\nThis legislative purpose applies to the instant proceeding. The legislature\u2019s intent that adoption records remain confidential would be frustrated if names of the parties were disclosed here on appeal. We recognize that the underlying petition was filed on the trial court\u2019s MR calendar and not in the adoption case number. However, the parties ought not be able to do indirectly what the legislature has prohibited them from doing directly; that is, the parties filed pleadings below naming everyone involved in a case number where the records do not fall under section 18(c) of the Adoption Act (750 ILCS 50/18(c) (West 1998)). The legislature may choose to address this omission by future legislation. In the meantime, the courts must endeavor to protect, as best they can, the confidentiality of all parties.\nThus, we recommend that parties involved in similar appeals from adoption-related proceedings (1) use pseudonyms and (2) redact and substitute the pseudonyms for any identifying information contained in documents appended to their briefs, as these are public documents in this court\u2019s records. That portion of the Illinois Supreme Court\u2019s General Administrative Order on Recordkeeping in the Circuit Courts, dated May 20, 1968, that provides procedures by which adoption records maintained by the circuit clerks are to be impounded or sealed (Administrative Office of the Illinois Courts, Manual on Recordkeep-ing \u00a7 L (2d ed. 1996)), as discussed in section 18(c) of the Adoption Act (750 ILCS 50/18(c) (West 1998)), does not apply by its terms to the reviewing court, nor does any supreme court rule address impounding such records in reviewing courts.\nIV CONCLUSION\nFor the reasons stated, we affirm the trial court\u2019s judgment.\nAffirmed.\nCOOK, EJ., and MYERSCOUGH, J., concur.",
        "type": "majority",
        "author": "JUSTICE STEIGMANN"
      }
    ],
    "attorneys": [
      "David E. Neely (argued), of Chicago, for appellant.",
      "Don C. Hammer, of Hayes, Hammer, Miles, Cox & Ginzkey, of Blooming-ton, for appellees.",
      "James E. Ryan, Attorney General, of Chicago (Joel D. Bertocchi, Solicitor General, and Patrick W. Carlson (argued), Assistant Attorney General, of counsel), for appellee Department of Children & Family Services.",
      "Richard W Zuckerman, of Law Office of Richard W Zuckerman, of Peoria, for appellee Baby Fold."
    ],
    "corrections": "",
    "head_matter": "In re J.D. (Jane Doe, Plaintiff-Appellant, v. John Noe et al., Defendants-Appellees).\nFourth District\nNo. 4-00-0001\nArgued July 19, 2000.\nOpinion filed November 21, 2000.\nRehearing denied December 19, 2000.\nDavid E. Neely (argued), of Chicago, for appellant.\nDon C. Hammer, of Hayes, Hammer, Miles, Cox & Ginzkey, of Blooming-ton, for appellees.\nJames E. Ryan, Attorney General, of Chicago (Joel D. Bertocchi, Solicitor General, and Patrick W. Carlson (argued), Assistant Attorney General, of counsel), for appellee Department of Children & Family Services.\nRichard W Zuckerman, of Law Office of Richard W Zuckerman, of Peoria, for appellee Baby Fold."
  },
  "file_name": "0419-01",
  "first_page_order": 439,
  "last_page_order": 448
}
