In re N.S.-R. — Illinois appellate court affirms termination of father’s parental rights

Case
In re N.S.-R., a Minor (The People of the State of Illinois v. Floyd S.)
Court
Illinois Appellate Court, Fourth District
Judge
Justice Grischow; Presiding Justice Steigmann (Illinois Supreme Court, 1989); Justice DeArmond
Date Decided
October 30, 2026
Docket No.
4-26-0682
Topics
parental rights; child neglect; reasonable progress; DCFS services
Source
Read the full opinion

Background

The State sought to terminate Floyd S.’s parental rights to N.S.-R., born in 2019. The child was adjudicated neglected in October 2024 after the mother was hospitalized for psychiatric issues and Floyd could not be reached until the following day. In December 2024, the McLean County circuit court made N.S.-R. a ward of the court and placed custody and guardianship with DCFS.

The termination petition alleged that Floyd failed to make reasonable progress toward N.S.-R.’s return during the nine-month period from October 31, 2024, through July 31, 2025. The trial court found him unfit and terminated his parental rights in May 2026. Floyd appealed only the unfitness finding.

The Court’s Holding

The Fourth District affirmed. It held that the trial court’s finding that Floyd failed to make reasonable progress during the specified nine-month period was not against the manifest weight of the evidence.

Although Floyd maintained some contact with the agency and completed assessments, the evidence showed he did not verify employment as required, did not remedy housing problems, did not participate in recommended individual counseling, and did not progress beyond supervised visitation. The court also noted continuing concerns about his parenting engagement and supervision. Those deficiencies meant the case had not advanced to a point where N.S.-R.’s return to Floyd’s care could be meaningfully discussed in the near future.

Key Takeaways

  • Reasonable progress is measured objectively by whether the parent’s progress would permit the child’s return in the near future.
  • Participation in some services does not establish reasonable progress when the underlying barriers to reunification remain uncorrected.
  • The court may consider conditions identified after removal, including housing and parenting concerns, when assessing reasonable progress.

Why It Matters

The decision underscores that a parent’s efforts and partial compliance are not enough if they do not lead to demonstrable progress toward safe reunification. Housing stability, recommended counseling, and progress in visitation may all bear on whether return home can realistically be considered.

This Rule 23 order is nonprecedential except as permitted by Illinois Supreme Court Rule 23(e)(1).

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