At a permanency review hearing, the court is essentially asking how well the previous disposition worked. If it is not working, the court has the power to make a change. The State argues the trial court was merely modifying an order of visitation and cites several cases in which courts modified or curtailed visitation due to changed circumstances since the original visitation order was entered, which orders were reviewed under an abuse of discretion standard rather than for whether the orders complied with section 2-25. Visitation modifications may be made where circumstances warrant without resorting to the requirements of section 2-25. 307 Ill. App.
Ample evidence supports the trial court's position.
Respondent's failure to get the counseling he has been ordered to obtain while continuing to maintain a close relationship with the minors through his regular visits has contributed to the children's false hopes that their family will be reunited in the near future. Such false hopes are certainly not in the best interests of the children. The father's recalcitrance may make it impossible for him to be reunited with the children. Respondent's reported attitude of disinterest in obtaining the needed counseling, and his obvious failure to do so, is a justifiable basis for the suspension of visitation. The order of the trial court suspending respondent's visitation rights until he has obtained counseling is affirmed.