Background
Edward B. appealed the termination of his parental rights to A.V., born in March 2020. The State alleged that he was unfit because he failed to make reasonable progress toward A.V.’s return during the nine-month period from October 15, 2024, through July 15, 2025. The trial court found him unfit and later determined that termination was in A.V.’s best interests; Edward did not challenge the best-interest finding on appeal.
During the relevant period, Edward completed outpatient substance-abuse treatment, attended counseling and a domestic-violence program, and attended visits. But he missed about nine drug screens, had a THC-positive screen in November 2024, lacked a recovery plan, and continued to have poor insight and judgment. A psychologist found that he did not adequately understand the risks posed by domestic violence, substance abuse, and untreated mental-health issues, and opined that A.V. would be at high risk if returned to his care.
The Court’s Holding
The Illinois Appellate Court, Fourth District, affirmed. It held that the trial court’s finding that Edward was unfit for failing to make reasonable progress toward reunification was not against the manifest weight of the evidence.
The court applied the objective reasonable-progress standard, asking whether Edward’s compliance and progress were sufficiently demonstrable that the trial court could return A.V. to him in the near future. Although Edward had participated in services and his visits generally went well, the evidence showed he had not established independent living, safe and appropriate housing, adequate parenting boundaries, or a sustained plan for sobriety and safe care.
Key Takeaways
- Participation in services does not alone establish reasonable progress toward reunification.
- The court may consider whether a parent’s housing, sobriety plan, insight, and parenting ability would permit a near-term return of the child.
- Because the best-interest ruling was not challenged, the appeal turned solely on the unfitness finding.
Why It Matters
The decision underscores that Illinois’s reasonable-progress inquiry is forward-looking and practical: the question is whether the parent’s progress would allow the child’s safe return in the near future. Attendance and some improvement may be insufficient where unresolved safety, housing, substance-abuse, and parenting concerns remain.