Background
K.B. was taken into DCFS custody shortly after his 2023 birth, when he experienced withdrawal symptoms and remained in neonatal intensive care. The circuit court adjudicated him neglected and required his father, Delorian B., to complete counseling, domestic-violence services, parenting education and coaching aimed at emotional regulation and safe parenting.
Although Delorian completed some services and had positive visits with K.B., the record reflected continuing verbal aggression toward providers, missed or disrupted visits, unstable and unapproved housing, lack of income verification, and incomplete engagement with housing-assistance services. He also did not attend K.B.’s medical appointments despite K.B.’s autism and pica diagnoses. After Delorian’s October 2025 incarceration, the State sought termination.
The Court’s Holding
The Illinois Appellate Court affirmed. It held that the circuit court’s finding of parental unfitness was not against the manifest weight of the evidence. Delorian’s partial participation in services did not outweigh evidence that he repeatedly failed to regulate his behavior, obtain suitable housing, work consistently with providers, or demonstrate that he could apply services to meet K.B.’s needs.
The court also concluded that the evidence supported findings that Delorian failed to maintain a reasonable degree of interest, concern, or responsibility for K.B.’s welfare and failed to make reasonable efforts and progress toward reunification. Because one proven unfitness ground is sufficient and Delorian did not challenge the best-interests finding, termination was proper.
Key Takeaways
- Completing some services does not establish fitness if a parent does not demonstrate meaningful behavioral change.
- Persistent housing instability and failure to engage with offered assistance can support unfitness findings.
- A parent’s failure to learn about and address a child’s special needs may support a finding of insufficient interest, concern, or responsibility.
Why It Matters
The decision underscores that reunification services are evaluated by their practical results, not simply by attendance or completion. Courts may consider a parent’s ongoing conduct, engagement with providers, stability, and ability to meet the child’s particular needs when assessing unfitness.