Background
The State initiated neglect proceedings concerning K.W. and A.W. after K.W. was hospitalized and tested positive for marijuana and cocaine that had been accessible in the mother’s residence. A separate petition was later filed concerning newborn B.C. because the mother had not attained fitness in the older children’s cases. The trial court adjudicated all three children neglected, made them wards of the court, and placed their custody and guardianship with the Illinois Department of Children and Family Services.
The State subsequently petitioned to terminate the mother’s parental rights, alleging that she failed to make reasonable efforts to correct the conditions leading to removal and failed to make reasonable progress toward reunification during the nine-month period from November 20, 2024, through August 20, 2025. Evidence showed missed drug screens and visits, positive tests for THC and alcohol, unstable housing, incomplete services, and failure to disclose a new relationship. The trial court found the mother unfit on both grounds and, after a best-interest hearing, terminated her parental rights.
The Court’s Holding
The appellate court affirmed, holding that the trial court’s finding that the mother failed to make reasonable progress toward the children’s return was not against the manifest weight of the evidence. Reasonable progress is measured objectively and requires demonstrable movement toward reunification sufficient for the court to conclude that the children could be returned to the parent in the near future.
Although the mother had made some initial progress, the evidence showed that her progress deteriorated during the relevant nine-month period. She missed visits with her caseworker and children, continued using marijuana, missed numerous drug screens, tested positive for THC and alcohol, lacked stable housing, did not consistently verify employment, failed to complete all required services, and did not disclose a relationship with a new boyfriend. Because one supported statutory ground was sufficient to establish unfitness, the appellate court did not address the separate reasonable-efforts finding. The mother did not challenge the best-interest determination on appeal.
Key Takeaways
- A parent makes reasonable progress only through objectively demonstrable movement toward reunification that could permit the children’s return in the near future.
- Missed visits and drug screens, continuing substance use, unstable housing, incomplete services, and undisclosed relationships supported the finding that the mother had not made reasonable progress.
- Because a single proven statutory ground is enough to establish parental unfitness, the court declined to review the trial court’s alternative reasonable-efforts finding.
Why It Matters
The order illustrates that completing some services does not by itself establish reasonable progress when the parent later regresses or remains unable to provide a stable and safe home. Illinois courts evaluate progress objectively based on whether reunification is realistically attainable in the near future.
The decision also underscores the importance of appellate issue selection: the mother challenged only the fitness determination, leaving the trial court’s best-interest ruling unchallenged.