People v. Filemon M.

Petitions for adjudication of wardship were filed on behalf of minors A.M. and E.M. based on allegations made by the minors’ 17-year-old sister, Rosa M., that their father had sexually abused her. At the adjudication hearing, Rosa recanted her prior statements. The trial court found the recantation credible and dismissed the petitions for adjudication of wardship. The public guardian and the State appeal from this dismissal.1

On appeal, the petitioners argue that the trial court erred in refusing to allow impeachment of Rosa’s in-court recantation and in precluding inquiry into the father’s…