Background
Lakeia B.’s three daughters entered DCFS care in June 2023 following domestic violence between their parents. The children were adjudicated neglected after Lakeia admitted that unresolved domestic-violence issues placed them at risk. Although she completed parenting and domestic-violence programs, maintained housing and employment, and attended successful visits, the children’s father did not complete comparable services.
The caseworker warned Lakeia that continued contact with the father would prevent reunification, and the trial court later expressly ordered her to have no contact with him. Nevertheless, jail records showed that the father placed numerous calls to Lakeia’s phone, many of which she answered. Lakeia repeatedly denied the contact before eventually admitting it. The trial court found her unfit for failing to make reasonable progress during the alleged nine-month period and later found termination to be in the children’s best interests.
The Court’s Holding
The appellate court affirmed the unfitness finding, holding that it was not against the manifest weight of the evidence. Although Lakeia completed recommended services, reasonable progress required demonstrable movement toward reunification in light of the domestic violence that caused the children’s removal. Her continued relationship with the father, violation of the no-contact order, repeated denials, and failure to accept responsibility supported the conclusion that she had not acquired the skills needed to parent safely and that reunification was unlikely in the near future.
The court also affirmed the best-interest finding. The children had lived with their foster mother for more than two years, were thriving and bonded to her, and had their needs met in the placement. The foster mother was willing to adopt them and continue their relationship with Lakeia. The court rejected reliance on an asserted 2032 parole date for the father because that information had not been introduced in the trial court, which instead heard that he might be released within a year. The children’s need for permanence and stability supported termination.
Key Takeaways
- Completing required services does not by itself establish reasonable progress when a parent’s conduct shows that the underlying safety problem remains unresolved.
- Continued contact with an abusive, noncompliant parent—particularly in violation of a court order—and dishonesty about that contact may support an unfitness finding.
- A stable, successful foster placement offering adoption and continued family relationships may support a finding that termination is in the children’s best interests.
Why It Matters
The decision illustrates that Illinois courts evaluate reasonable progress objectively and focus on whether a child can likely be returned safely in the near future, not merely whether a parent has checked off required services. Conduct inconsistent with lessons from domestic-violence and parenting programs can outweigh formal compliance.
It also underscores the importance of the appellate record: information obtained from an outside website cannot undermine a best-interest determination when it was not presented to the trial court.