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Respondent next posits that the order barring her frompresenting a defense at trial abridged the rights afforded herunder the Juvenile Court Act⁽⁴⁾ (705 ILCS 405/1-5 (West 1998)) andoffended her constitutional right to due process. We agree. The nature of the process due in parental rights terminationproceedings turns on a balancing of the three factors specifiedin Mathews v. Eldridge, 424 U.S. 319, 335, 47 L.Ed.2d 18, 33, 96S.Ct. 893, 903 (1976). See also In re C.J., 272 Ill. App. 3d461, 465 (1995); Lassiter v. Department of Social Services, 452U.S. 18, 68 L. Ed. 2d 640, 101 S. Ct. 2153 (1981). According toMathews, the factors to be considered are: (1) the privateinterest that will be affected by the official actions; (2) therisk of an erroneous deprivation of such interest through theprocedures used, and the probable value, if any, of additional orsubstitute procedural safeguards; and (3) the government'sinterest, including the function involved and the fiscal andadministrative burdens that the additional or substituteprocedural requirement would entail. Mathews v. Eldridge, 424U.S. at 335, 47 L. Ed. 2d at 33, 96 S. Ct. at 903.

In parental rights termination proceedings, the privateinterest affected is commanding; the risk of error resulting frombarring a parent from testifying manifest; and the governmentalinterest is coextensive with that of the natural parent up to adetermination of unfitness. Consequently, we conclude that barring a party in interest from presenting a defense ortestifying in such proceedings does not comport with due process.

It is well established that a parent's interest inmaintaining a parental relationship with her child is afundamental liberty interest protected by the due process clauseof the fourteenth amendment. Santosky v. Kramer, 455 U.S. 745,71 L. Ed. 2d 599, 102 S. Ct. 1388 (1982)⁽⁵⁾; U.S. Const., amend.XIV. Indeed, the Supreme Court recognized that a parent's desirefor and right to the companionship, care, custody and managementof his or her children is an interest far more precious than anyproperty right. Santosky, 455 U.S. at 758-59, 71 L. Ed. At 610,102 S. Ct. at 1397. Thus, "[w]hen the state initiates a parentalrights termination proceeding, it seeks not merely to infringethat fundamental liberty interest, but to end it. *** Few formsof state action are both so severe and so irreversible." Santosky, 455 U.S. at 759, 71 L. Ed. 2d at 610, 102 S. Ct. at1397-98. See also In re D.R., 307 Ill. App. 3d 478, 482 (1999).

In recognition of the significant interest in jeopardy intermination of parental rights cases, the Supreme Court held that state intervention to terminate the relationship between a parentand a child must be accomplished by procedures meeting therequisites of the Due Process Clause. Lassiter v. Department ofSocial Services, 452 U.S. 18, 68 L. Ed. 2d 640, 101 S. Ct. 2153(1981). "If anything, persons faced with forced dissolution oftheir parental rights have a more critical need for proceduralprotections than do those resisting state intervention intoongoing family affairs." Santosky, 455 U.S. at 753, 71 L. Ed. 2dat 606, 102 S. Ct. at 1395. Thus, the first Mathews factorweighs heavily against the trial court's restriction of aparent's meaningful participation in the proceeding undertaken toterminate his or her parental rights.

We must next consider both the risk of erroneous deprivationof private interests resulting from barring a parent frompresenting evidence at a termination proceeding and thelikelihood that the utilization of other procedures would reducethat risk.

Although the Juvenile Court Act specifically states theproceedings are not intended to be adversarial in nature (705ILCS 405/1-5(1) (West 1998)), in actuality proceedings toterminate parental rights are contests that pit the statesquarely against the parents and, as the Supreme Court stated inSantosky, bear indicia of a criminal proceeding. 455 U.S. at 762, 71 L. Ed. 2d at 612, 102 S. Ct. at 1399. Such proceedingsare begun by the filing of a petition containing specific factualallegations sufficient to declare the minor abused, neglected ordependent. 705 ILCS 405-2/13(2) (West 1998). The State, thechildren and the parents are all represented by counsel. 705 ILCS405/1-5, 1-6, 2-17 (West 1998). Each party attempts tosubstantiate its respective position by the introduction ofevidence and witness testimony at the hearing. 705 ILCS 405/2-18(West 1998). The judge then makes a determination of whether theState has shown by clear and convincing evidence that a parent isan unfit person as defined in the Adoption Act (750 ILCS 50/1(West 1998)). 705 ILCS 405/2-29(2) (West 1998). The statuteclearly provides a blueprint for a legal process which, byapplication if not by intent, is adversarial in nature. Thequestion then is, given the substantial liberty interest at issueand the adversarial nature of the proceedings, whether barring aparent from presenting a defense may result in an erroneousdeprivation of those interests. We answer in the affirmative.

The fundamental requirement of due process is theopportunity to be heard at a meaningful time and in a meaningfulmanner. Mathews, 424 U.S. at 333, 47 L. Ed. 2d at 32, 96 S. Ct.at 902. The "'right to be heard before being condemned to suffergrievous loss of any kind, even though it may not involve thestigma and hardships of a criminal conviction, is a principle basic to our society.'" Mathews, 424 U.S. at 333, 47 L. Ed. 2dat 32, 96 S. Ct. at 902, quoting Joint Anti-Fascist Committee. v.McGrath, 341 U.S. 123, 168, 95 L. Ed. 817, 852, 71 S. Ct. 624,646-7 (1951). This court has recognized the natural parent mustbe afforded the opportunity to participate in the proceeding in ameaningful manner in order to comport with due processrequirements. See In re C.J., 272 Ill. App. 3d 461(1995)(incarcerated parent does not have absolute right to bepresent at hearing but must have opportunity to participate inproceeding); In re D.R., 307 Ill. App. 3d 478 (1999) (wheremother was not present at hearing, court violated her right todue process by barring her attorney from presenting a defense andcross-examining State witnesses).

Both the State and the public guardian cite In re E.L., 152Ill. App. 3d 25 (1987), in support of their argument thatrespondent, by her own wilful refusal to sign the answers to interrogatories, forfeited her right to be heard. In E.L., thiscourt stated "[d]ue process is not denied when a party fails toavail himself of the opportunity to be heard after it is offeredto him." 152 Ill. App. 3d at 33. We find this precedent to beinapplicable to the instant case. First, the State in E.L.sought only an adjudication of wardship, not a termination of thenatural parents' rights. Second, both parents in E.L. wererepresented by counsel, presented evidence and testified on their own behalf. Moreover, the due process violation alleged onappeal in E.L. did not concern an abrogation of respondents'right to meaningfully participate in the hearing process. Finally, we do not believe it a fair characterization thatrespondent in the case at bar "failed to avail" herself of theopportunity to be heard. Certainly her intransigence in refusingto sign the interrogatories created an obstruction in the orderlyprocession of the case. However, there were certainly much lessrestrictive measures the court could have taken to remedy thesituation that would not have encroached on respondent's dueprocess rights or worked a hardship on the court.

The purpose of the discovery process is to ascertain thetruth and eliminate the element of surprise at trial. In reHenry, 175 Ill. App. 3d 778, 785 (1988). Supreme Court Rule219(c) authorizes the court to impose sanctions, includingbarring an offending party from maintaining any particular claimor defense. 166 Ill. 2d R. 219(c)(iii). However, the purpose ofimposing sanctions is to coerce compliance with the rules andorders, not to punish the dilatory party. Sander v. Dow ChemicalCo., 166 Ill. 2d 48, 68 (1995). Therefore, due to the drasticconsequences that necessarily flow from the imposition of severesanctions, they should only be imposed in the most extreme casesas a last resort to enforce discovery rules. See Sander v. DowChemical Co., 166 Ill. 2d at 68; In re D.R., 307 Ill App. 3d at 482; Kmoch v. Klein, 245 Ill. App. 3d 308, 313 (1993). Webelieve this to be a particularly pertinent principle intermination of parental rights cases due to the fundamentalnature of the interest in jeopardy and the increased likelihoodof a natural parent being erroneously deprived of his or herchild.

In the instant case, respondent's attorney indicated to thecourt she had prepared answers to the interrogatories on herclient's behalf that respondent simply refused to sign. As onealternative to completely barring a defense, the court could haveasked respondent to swear to the completeness and accuracy ofthose answers as well as any number of other possible alternativecourses of action.

Finally, we must consider the State interests at stake inparental rights determinations. The government's function insuch proceedings is in its role as parens patriae - promoting thewelfare of the child and an administrative interest in reducingthe cost and burden of such proceedings. Santosky, 455 U.S. at766, 71 L. Ed. 2d at 615, 102 S. Ct. at 140; In re C.J., 272Ill. App. 3d at 466. The parens patriae interest favorspreservation, not severance, of the natural familial bonds. 705ILCS 405/1-2 (West 1998); Santosky, 455 U.S. at 766-67, 71 L. Ed.2d at 615, 102 S. Ct. at 1401.

Clearly, the State's interest in preserving the integrity ofthe family unit would be undermined by considering only thatevidence marshalled by the State representative of therespondent's parenting deficiencies. It is evident there is aconfluence of purpose between the State as parens patriae and thenatural parent at all points prior to a determination ofunfitness.

The logical conclusion of this balancing process is thatrespondent's due process rights were violated by the court'ssanction barring her from presenting a defense where there wereless severe alternatives available and respondent's libertyinterests in her children were at risk of erroneous deprivationif the court failed to hear evidence in support of respondent'sexpressed desire to reunite her family. Therefore, we remandthis cause for a hearing in which the respondent may participate.

Reversed and remanded.

O'MARA FROSSARD, P.J., and GALLAGHER, J., concur.

1. ¹ The children's father, Wayne C., voluntarily consented tothe adoption of the two girls by his mother, Lorraine Harry, withwhom the girls have lived since being taken from their parents'home.

2. ² "Subject to the rules of the Supreme Court, the circuitand Appellate Courts may make rules regulating their dockets,calendars, and business." 735 ILCS 5/1-104(b) (West 1998).

3. ³ Respondent additionally argues the trial court abused itsdiscretion in granting the State's motion for sanctions as theState failed to first get leave of court to serve respondent withthe subject interrogatories. This argument is clearly incontradiction to the plain meaning of circuit court rule 19A.12,which provides that the parties may conduct limited discoverywithout leave of court.

4. ⁴ In relevant part the Juvenile Court Act provides:

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