Due process requires that notice in juvenile proceedings be equivalent to that constitutionally required in civil and criminal cases. In re T.A., 181 Ill. App.3d 1034, 1037 (1989), citing In re Gault, 387 U.S. 1, 18 L. Ed. 2d 527, 87 S. Ct. 1428 (1967). In a juvenile proceeding, due process requires adequate notice to a minor and his parents.
) Through the notice provisions of the Act, the legislature has therefore determined that parents are necessary respondents who must be named and served with notice in order for the trial court to conduct an adjudicatory hearing. People v. R.S. (1984), 104 Ill.2d 1, 6; In re T.A. (1989), 181 Ill. App.3d 1034, 1038. Respondent contends that his father did not receive notice of the adjudicatory hearing as required by the statute and this lack of notice rendered the proceedings below void.
( In re P.W. (1988), 178 Ill. App.3d 522, 528, 533 N.E.2d 922; In re R.W. (1988), 176 Ill. App.3d 868, 874-75, 531 N.E.2d 294.) Where a parent has appeared and participated in all proceedings before the circuit court, and does not object to jurisdiction, she has waived the formality of service of process and voluntarily submits to the jurisdiction of the court. ( In re J.W. (1981), 87 Ill.2d 56, 429 N.E.2d 501; In re T.A. (1989), 181 Ill. App.3d 1034, 537 N.E.2d 1118.) Furthermore, where there is no showing that any substantial interest of the minor was prejudiced by failure to obtain personal service on the minor, the court's decision is not void for lack of jurisdiction. In re Pronger (1987), 118 Ill.2d 512, 524, 517 N.E.2d 1076; In re P.W. (1988), 178 Ill. App.3d 522, 528, 533 N.E.2d 922; In re R.W. (1988), 176 Ill. App.3d 868, 874-75, 531 N.E.2d 294.
"Unfortunately, the procedural requirements of the Act are frequently ignored. For over 20 years, Illinois appellate courts have recognized a lack of attention to the procedural requirements of the Act by trial courts (see In re T.A., 181 Ill. App. 3d 1034, 1039, 537 N.E.2d 1118, 1121 (1989) ('we also note the lax attention by the trial court to the procedural requirements of the Juvenile Court Act')) and the State (see In re L.C.C., 167 Ill. App. 3d 670, 673, 521 N.E.2d 652, 654 (1988) ('An increasing number of cases suggest the State is inattentive to the notice requirements of the [Juvenile Court] Act')). In this case, the trial court, the State, and the respondent minor's counsel all ignored the Act's notice requirements.
Unfortunately, the procedural requirements of the Act are frequently ignored. For over 20 years, Illinois appellate courts have recognized a lack of attention to the procedural requirements of the Act by trial courts (see In re T.A., 181 Ill. App. 3d 1034, 1039, 537 N.E.2d 1118, 1121 (1989) ("we also note the lax attention by the trial court to the procedural requirements of the Juvenile Court Act")) and the State (see In re L.C.C., 167 Ill. App. 3d 670, 673, 521 N.E.2d 652, 654 (1988) ("An increasing number of cases suggest the State is inattentive to the notice requirements of the [Juvenile Court] Act")). In this case, the trial court, the State, and the respondent minor's counsel all ignored the Act's notice requirements.
The same waiver rule applies to parents. In re J.W. (1981), 87 Ill.2d 56, 429 N.E.2d 501; In re T.A. (1989), 181 Ill. App.3d 1034, 537 N.E.2d 1118. • 2 In the case at bar, respondent appeared in response to a juvenile petition alleging delinquent acts; he was represented by counsel; he made no objection to the court's jurisdiction; his parents had actual notice and attended many of the proceedings; and he participated fully in the proceedings.