Background
DCFS took Paisleigh, then four years old, into protective custody after an alleged domestic-violence incident in which her father punched Mother and broke a window while Paisleigh was home. The circuit court later adjudicated Paisleigh neglected and at substantial risk of physical abuse because of domestic violence in the home.
Mother’s service plan required mental-health treatment, parenting services, domestic-violence services, drug screening, housing and financial stability, and visitation. Although she completed domestic-violence services and one parenting program, she was repeatedly discharged from or failed to complete mental-health and additional parenting services, attended fewer than half of her drug screens, lacked stable employment, and substantially reduced her visitation. In 2025, she attended 13 of 50 offered visits.
The Court’s Holding
The appellate court affirmed the termination of Mother’s parental rights. It held that the unfitness finding was not against the manifest weight of the evidence because Mother failed to make reasonable progress toward Paisleigh’s return during the alleged nine-month periods. Her completion of domestic-violence services did not overcome her failure to substantially fulfill the rest of the service plan, including mental-health treatment, parenting requirements, drug screening, stability, and visitation.
The court also upheld the best-interest finding. Although Paisleigh had lived with her paternal aunt and uncle for only about a month before the hearing, the evidence showed she was safe, happy, healthy, and thriving there; had connections to the relative family, grandmother, and cousins; called her aunt and uncle “mom” and “dad”; and had a placement willing to provide permanency. Those circumstances supported termination despite Mother’s bond with Paisleigh and the placement’s short duration.
Key Takeaways
- A single proven statutory ground—here, failure to make reasonable progress—supports an unfitness finding.
- Reasonable progress requires substantial compliance with available service-plan obligations, not completion of only one service.
- A new relative placement can support termination when the evidence shows safety, attachment, family continuity, and a realistic path to permanence.
Why It Matters
The decision underscores that domestic violence may initiate a neglect case, but a parent’s progress is assessed across all court-ordered services and conditions affecting reunification. At the best-interest stage, the child’s need for a stable and permanent family setting controls, even when the parent-child relationship remains meaningful.