Background
B.C. was removed from her mother, Casey D., after allegations that B.C.’s father sexually assaulted B.C.’s older half-sister, L.C. The mother initially defended the father and declined to keep the children from him, though she later said she would end the relationship and seek an order of protection.
The State later sought to terminate the mother’s parental rights. Although she completed several services and attended supervised visits, evidence showed she repeatedly denied continuing contact with the father despite surveillance photographs placing her at his residence, including an image that appeared to show them kissing. She also admitted she had lied to the court under oath.
The Court’s Holding
The Illinois Appellate Court affirmed the finding that the mother was unfit for failing to make reasonable progress toward B.C.’s return during the specified nine-month period. Her lack of candor with DCFS and service providers about her continued relationship with the father supported the conclusion that she had not substantially fulfilled her service-plan obligations or genuinely engaged in services.
The court emphasized that completing services does not alone establish reasonable progress. A parent must also correct the conditions that brought the child into care and cooperate meaningfully with the process. Because one proven ground of unfitness sufficed, the court did not review the separate finding that the mother failed to maintain a reasonable degree of interest, concern, or responsibility for B.C.
Key Takeaways
- Reasonable progress requires more than checking off service-plan tasks; it requires meaningful, good-faith engagement.
- A parent’s dishonesty with DCFS and evaluators can constitute substantial noncompliance with a service plan.
- The court held that the unfitness finding rested on the mother’s lack of cooperation and candor, not on a categorical ban on contact with B.C.’s father.
Why It Matters
The decision underscores that courts may consider whether a parent has internalized services and dealt honestly with safety concerns, even when the parent has completed evaluations, classes, assessments, testing, and visits. The appellate court also rejected the argument that the mother needed a specific warning that continued contact with the father would itself result in termination, because the dispositive issue was her repeated misrepresentations and failure to cooperate.