Background
K.R. was adjudicated neglected after her siblings were removed from Kayla S.’s care. DCFS received custody in 2022. The State later sought to terminate Kayla’s parental rights, alleging that she failed to maintain reasonable interest in K.R. and failed to make reasonable progress toward reunification between July 9, 2023, and April 9, 2024.
Although Kayla participated in counseling, maintained employment, obtained housing, and eventually bought her own vehicle, the trial court found that her volatile and on-and-off relationship with K.R.’s father continued to create power-and-control concerns and interfered with reunification. K.R. had lived with her foster family since December 2022 and regarded them as her parents.
The Court’s Holding
The appellate court affirmed. It held that the finding of unfitness for failure to make reasonable progress was not against the manifest weight of the evidence. The evidence supported the trial court’s conclusion that, despite Kayla’s efforts and some concrete gains, she had not sufficiently demonstrated changed decision-making, stability, or parenting capacity to permit K.R.’s return in the near future.
The court also held that Kayla forfeited her claim that the agency’s failure to offer particular domestic-violence and videotaped-parenting services prevented a reasonable-progress finding because she did not adequately develop the argument with supporting authority. Because one unfitness ground was supported, the court did not address the alternative interest-concern-responsibility ground. Finally, termination was in K.R.’s best interest because her foster parents provided stability, met her needs, supported sibling and parental contact, and wished to adopt her.
Key Takeaways
- Reasonable progress turns on whether a parent’s progress would allow return home in the near future, not merely on participation in services.
- A parent’s relationship dynamics and lack of candor with the agency may be relevant where they remain barriers to reunification.
- At the best-interest stage, the child’s stability, attachments, and need for permanence control the analysis.
Why It Matters
The decision illustrates that substantial efforts and improvements in housing, employment, and transportation may not establish reasonable progress when unresolved safety and parenting concerns still prevent reunification. It also underscores that appellate arguments about allegedly unavailable services must be fully developed and supported by authority.