Does Inability of State to Find a Paying Child Support Parent That Was ''easy to Locate'' Deny Due Process ?

In In re C.H., 277 Ill. App. 3d 32, 660 N.E.2d 545, 214 Ill. Dec. 100 (1995) the evidence showed that the respondent's father had been paying child support for the respondent and had worked at the same job for 18 years. In re C.H., 277 Ill. App. 3d at 35. Because of these facts, the court in In re C.H. concluded that the father was easy to locate and the State's failure to "exercise even a small degree of diligence," through which it could have located the father, denied the respondent due process of law. In re C.H., 277 Ill. App. 3d at 35. In so holding, the court distinguished other cases in which the courts had found that a lack of notice to a noncustodial parent did not deny due process because in those cases there was no evidence the noncustodial parent was paying child support, it would have been difficult to locate those parents, and there had been no evidence of any significant relationship between the respondents and the noncustodial parents. In re C.H., 277 Ill. App. 3d at 35.