Background
Hope R. gave birth to G.R. in December 2023. The State of Illinois filed a neglect petition in December 2023, alleging G.R.’s environment was injurious to her welfare. Hope had a history of prior child welfare cases where she either surrendered parental rights or had them terminated, based on ongoing domestic violence and lack of parental ability. The petition also detailed Hope’s August 2021 violent altercation with G.R.’s putative father, October 2021 threats from that same individual, Hope’s unmedicated bipolar disorder, and multiple prior Department of Children and Family Services (DCFS) findings of substantial risk of injury. G.R. was placed in foster care in December 2023 with a stable family that had also become the foster/adoptive family for four of G.R.’s five biological siblings.
Hope was ordered to engage in services including individual counseling, monthly drug screening, a domestic violence class, a parenting class, and cooperation with DCFS. During the nine-month period from November 26, 2024, through August 26, 2025, Hope’s compliance was inconsistent. She completed only five of nine scheduled drug drops (one tested positive for THC), despite reporting both marijuana and ecstasy use while pregnant. She failed to complete a drug and alcohol assessment, missed 13 of 32 possible visits with G.R., and missed four individual counseling sessions in July-August 2025. While Hope maintained stable employment and housing and had completed a domestic violence class and two parenting classes prior to this period, the trial court found her lack of consistent engagement, particularly in the final six months, demonstrated insufficient progress toward reunification.
The Court’s Holding
The Illinois Appellate Court affirmed the trial court’s termination of Hope’s parental rights. The court held that the trial court’s finding of unfitness was not against the manifest weight of the evidence. Under Illinois law (750 ILCS 50/1(D)(m)(ii)), a parent can be found unfit for failing to make “reasonable progress” toward a child’s return during any nine-month period. “Reasonable progress” is defined as “measurable or demonstrable movement” toward that goal—an objective standard measured by whether progress is “sufficiently demonstrable” and of such quality that the child could realistically be returned to parental custody in the near future.
The appellate court found the evidence clearly supported the trial court’s conclusion that Hope failed this objective standard. Despite some positive steps (stable employment and housing, completed classes), Hope’s inconsistent compliance with ordered services—particularly missing one-third of visits and four counseling sessions, completing only five of nine drug drops with one positive result, and refusing to cooperate with home safety checks—demonstrated she could not provide for G.R.’s return in the foreseeable future. The court also affirmed the best-interests determination, noting that G.R. had lived with her foster family since six months old, was bonded to them as her only parental figures, lived with five siblings (four already adopted by the foster parents), and that the foster parents provided stability, love, and sought to provide permanency through adoption.
Key Takeaways
- Termination of parental rights requires a two-step showing: unfitness by clear and convincing evidence, then that termination serves the child’s best interests by preponderance of the evidence.
- The “reasonable progress” standard is objective, not subjective—courts measure whether a parent’s compliance is demonstrable enough that the child could realistically return to custody in the near future, not merely whether some progress occurred.
- Trial courts have broad discretion in child welfare matters and appellate courts reverse unfitness or best-interests findings only when they are against the manifest weight of the evidence.
- Sibling placement and continuity with an established foster family are significant factors favoring termination when the child has bonded exclusively to those caregivers since infancy.
Why It Matters
This decision reinforces Illinois courts’ commitment to an objective standard for “reasonable progress” in termination cases, rejecting a subjective view that any progress suffices. The opinion clarifies that compliance must be sufficient to realistically support reunification in the near future, not merely demonstrate effort over time. This has practical implications for parents in dependency cases: isolated compliance or completion of some services does not guarantee avoiding termination if overall progress is fragmentary or concentrated early in the relevant period with deterioration later.
The decision also illustrates Illinois courts’ careful balancing of parental rehabilitation potential against children’s need for permanence and stability. When a child has lived exclusively with foster parents since early infancy and is bonded to them as sole parental figures, while also maintaining sibling relationships in the same home, courts will readily find that permanency through adoption serves the child’s best interests even absent evidence of parental abuse or abandonment. This supports permanency planning that prioritizes children’s emotional and relational stability over extended rehabilitation attempts.