Background
The State sought to terminate Mehkii J.’s parental rights to V.M. and S.M. after the children were removed in 2023. The case began after the father, who had substance-abuse issues, had cocaine accessible to V.M. while caring for the child. The court later found the children neglected and made them wards of the court.
Mehkii was required to complete parenting, counseling, and domestic-violence services, maintain housing, and cooperate with the agency. The State alleged that she failed to make reasonable efforts and reasonable progress during two statutory nine-month periods. Evidence showed repeated housing instability, incomplete or unsuccessful services, visitation concerns, and her continued relationship with the father despite domestic violence and repeated warnings that the relationship impeded reunification.
The Court’s Holding
The appellate court affirmed the unfitness finding. It held that the finding was not against the manifest weight of the evidence because Mehkii failed to make reasonable progress toward reunification during either charged nine-month period. Although she completed parenting classes, she did not substantially fulfill her service-plan obligations or correct the conditions preventing the children’s return, particularly her continued relationship with the father.
The court lacked jurisdiction to review the best-interests ruling terminating Mehkii’s parental rights. Her June 5, 2026 notice of appeal identified only the May 21 unfitness order, not the separate June 4 best-interests and termination order. Because the orders followed separate hearings and contained distinct findings, the omission could not be cured by liberal construction of the notice.
Key Takeaways
- A single proven ground of unfitness supports termination; the court upheld the reasonable-progress ground for both alleged nine-month periods.
- Reasonable progress requires demonstrable progress sufficient to permit return of the children in the near future, not merely partial service participation.
- A notice of appeal must identify a later, separate best-interests termination order for the appellate court to review it.
Why It Matters
The decision underscores that service-plan compliance is assessed by whether it meaningfully moves a parent toward safe reunification. Here, the parent’s continued relationship with an abusive, substance-using partner was a central barrier to progress.
It also illustrates a jurisdictional trap in juvenile appeals: appealing an unfitness finding alone does not automatically bring a later best-interests termination order before the reviewing court.