Background
Manny J.-P. entered DCFS care shortly after his May 2021 birth based on allegations that his environment was injurious to his welfare. The case involved both parents, who had cognitive impairments. Manny was adjudicated neglected and made a ward of the court in 2022.
Over nearly five years, Mother received referrals for counseling, parenting education and coaching, visitation, and housing-related services. Although she participated to some extent and completed a 12-week parenting class, the evidence showed inconsistent attendance at visits and services, minimal improvement in parenting skills, and continuing home-safety concerns. Manny lived with the same foster family from June 2021, developed strong bonds there, and the foster parents wished to adopt him.
The Court’s Holding
The appellate court affirmed the termination order. It held that the evidence supported the circuit court’s finding that Mother was unfit both for failing to maintain a reasonable degree of interest, concern, or responsibility for Manny’s welfare and for failing to make reasonable progress toward his return during the January 9 through October 9, 2024 period.
Mother’s cognitive impairment did not require reversal. The circuit court had considered it, but evidence supported its finding that it did not prevent Mother from attending visits and available services more consistently or from addressing readily correctable safety hazards in the home. The court also upheld the best-interest ruling because Manny was safe, thriving, and strongly bonded in the foster home that had cared for him for nearly his entire life and was prepared to provide permanence through adoption.
Key Takeaways
- Inconsistent visitation, uneven service participation, and unsafe housing can support an unfitness finding for lack of reasonable interest, concern, or responsibility.
- Reasonable progress is assessed objectively by whether the child could likely be returned to the parent in the near future.
- At the best-interest stage, a child’s need for permanence and established bonds with foster caregivers may outweigh the parent-child relationship.
Why It Matters
The decision underscores that a parent’s disability must be considered, but it does not automatically excuse failures to engage consistently in available services or correct conditions that prevent safe reunification. It also emphasizes the centrality of stability and permanence once the case reaches the best-interest phase.