May a Prisoner (Incarcerated In Another State) Participate ''Telephonically'' In Legal Proceedings ?

In In re C.J., 272 Ill. App. 3d 461, 650 N.E.2d 290, 208 Ill. Dec. 833 (1995), this court ruled that the trial court violated a respondent's due process rights by holding a hearing to terminate the respondent's rights without the respondent's presence because the respondent was incarcerated in another state. The Court remanded the matter for the trial court to choose one of three alternative methods for the respondent's participation. One of these alternatives was to permit the respondent to participate in the proceedings telephonically.