Background
S.S., born in October 2023, was removed from respondent Elizabeth S.’s care in February 2024 after the State alleged that her mental-health issues created an injurious environment for the child. Elizabeth stipulated to neglect, and the Winnebago County circuit court made S.S. a ward of the court and placed custody and guardianship with DCFS.
DCFS required Elizabeth to address substance use, mental health, domestic violence, parenting skills, drug testing, and housing. The State later sought termination, alleging that she failed to maintain reasonable interest and failed to make reasonable efforts and progress during the statutory nine-month period from July 7, 2024, through April 7, 2025. After a fitness hearing and a subsequent best-interest hearing, the circuit court found her unfit and terminated her parental rights.
The Court’s Holding
The appellate court affirmed. It held that the finding that Elizabeth failed to make reasonable progress toward S.S.’s return during the nine-month period was not against the manifest weight of the evidence. One proven ground of unfitness was enough to sustain the termination ruling, so the court addressed only reasonable progress.
The evidence showed that Elizabeth did not successfully complete required services, participated in only one of 10 to 15 requested drug tests, did not complete substance-abuse, psychiatric, parenting, or domestic-violence services, lacked stable housing, and missed all visits from August through November 2024 despite offered transportation. She never advanced to unsupervised or overnight visitation. The court also rejected her argument that the circuit court could not consider pre-period assessments and service plans: those materials properly established the conditions requiring correction and the baseline against which progress was measured.
Key Takeaways
- A single supported statutory ground of parental unfitness sustains termination, even where multiple grounds were alleged.
- Reasonable progress is assessed objectively through compliance with service plans and whether the child could be returned in the near future.
- Documents predating the statutory progress period may be considered to identify the removal conditions and required services, though progress itself must be measured within the statutory window.
Why It Matters
The decision underscores that partial participation in services will not establish reasonable progress where the parent does not complete core requirements or make measurable movement toward safe reunification. It also clarifies that courts may use initial assessments and service plans as context for evaluating progress during the statutory period.