Background
Three children were removed from parental custody in June 2023 following domestic violence between their mother, Lakeia B., and their father, Michael R. After Lakeia petitioned for an order of protection alleging repeated physical abuse and threats by respondent, the trial court determined there was probable cause and immediate necessity to remove the children from the home. The State adjudicated the children neglected, finding they were living in an environment injurious to their welfare due to unresolved domestic violence and anger management issues. Michael R. had pleaded guilty to domestic battery in a related criminal case.
A service plan was established requiring respondent to complete domestic violence treatment, mental health counseling, parenting classes, and a substance abuse assessment; obtain stable housing and employment; cooperate with his DCFS caseworker; and maintain regular visitation with his children. Initially, from November 2023 through January 2024, respondent engaged with services, completing some requirements and visiting his children. However, in February 2024, after a disagreement with caseworker Hannah Snook, he unilaterally ceased all visitation and services, stating that “he doesn’t care.”
For the next 15 months, respondent neither visited his children nor participated in any court-ordered services or treatment. He did not attend hearings, did not contact his caseworker to inquire about the children, and did not send letters, cards, or gifts. Though briefly re-engaging in May 2025, he visited only once more (in September 2025) before his arrest in October 2025 for violating a no-contact order with the mother. In November 2025, the trial court held a fitness hearing and found respondent unfit under 750 ILCS 50/1(D)(b) for failing to maintain reasonable interest, concern, or responsibility toward his children’s welfare, resulting in termination of his parental rights.
The Court’s Holding
The appellate court affirmed, holding that respondent was unfit as a matter of law. Under Illinois’s Adoption Act, a parent may be found unfit for failure to maintain “a reasonable degree of interest, concern, or responsibility” as to the child’s welfare. All three elements must be present to avoid a finding of unfitness, and the interest, concern, and responsibility must be “objectively reasonable”—not merely some minimal showing. The court noted that failure to comply with a court-ordered service plan is “tantamount to objectively unreasonable interest, concern, or responsibility.” Relevant factors include the parent’s efforts to visit and maintain contact, regular and consistent visitation, participation in required services, and any actions that hinder or discourage visitation. If visitation is impractical, courts may consider alternative forms of contact such as letters, telephone calls, and gifts.
Applying these standards, the court found that although respondent had engaged in services briefly during two periods (November 2023 to January 2024, and May 2025 to September 2025), he voluntarily disengaged for well over half the duration of the case—a continuous 15-month period during which he neither visited his children nor participated in any required treatment or services. During that time, he took no actions to maintain contact with them. The court rejected respondent’s argument that his efforts were merely “inconsistent,” finding instead that a parent genuinely interested in reunification would not unilaterally abandon all visitation and services for 15 months simply because of anger and frustration. The fact that respondent made 88 phone calls to the children’s mother while in jail but never discussed the children and never contacted his caseworker or attorney further demonstrated his lack of concern for their welfare.
The court emphasized that respondent never completed domestic violence treatment—the core issue that triggered the children’s removal—and that completing only three services out of many required does not demonstrate reasonable interest, concern, or responsibility. The trial court’s determination that respondent failed to show objectively reasonable interest, concern, or responsibility was upheld. Following this unfitness finding, the trial court held a best-interest hearing and determined termination of parental rights was in the children’s best interest. DCFS was appointed guardian with authority to consent to adoption.
Key Takeaways
- A parent must maintain “objectively reasonable” (not merely some) degree of interest, concern, and responsibility; sporadic engagement interspersed with extended disengagement satisfies the unfitness standard under Illinois law
- Failure to comply with a court-ordered service plan constitutes unreasonable parental interest, concern, or responsibility, even when the parent initially showed some effort
- Regular visitation and active participation in required services are among the most critical factors; a 15-month absence from both, coupled with no alternative contact (letters, calls, gifts) and no inquiries about the children, strongly supports an unfitness finding
- A parent’s frustration with a caseworker or the child welfare system does not excuse non-compliance with court orders; courts will consider actions or statements that discourage or hinder visitation as evidence of lack of reasonable concern
Why It Matters
This decision provides crucial guidance on termination of parental rights in Illinois dependency cases and demonstrates that courts will not tolerate prolonged parental disengagement, even when a parent initially demonstrated some compliance with a service plan. For practitioners, the case illustrates that a parent who begins services, then abandons them for an extended period due to interpersonal conflict, will likely lose parental rights—even if the parent later re-engages briefly. The decision reinforces that parental interest and responsibility must be continuous and consistent, not sporadic or intermittent. Courts will look to the totality of the parent’s conduct and will not excuse extended absence as mere “inconsistency” when the absence is the parent’s voluntary choice.
For caseworkers and families, the opinion underscores the critical importance of documenting parental visitation attempts, service participation, and other forms of contact with children. The detailed record here—showing respondent’s multiple phone calls to the mother but zero contact with his children, no written communication, and complete non-participation in treatment—was dispositive. The decision also reaffirms that domestic violence remains a serious impediment to reunification and that a parent’s failure to complete domestic violence treatment is particularly weighty when domestic violence was the reason the children were removed from the home in the first place.