Background
Wesson H. entered protective custody shortly after his birth in April 2025 because his mother and the child tested positive for amphetamines and methamphetamine. Although Father initially tested negative, later drug screens were positive for THC, methamphetamine, and benzoxepines. DCFS required him to maintain safe housing, complete substance-abuse and mental-health assessments and recommended treatment, submit to random drug screens, participate in parenting education, and attend supervised visits.
Father initially attended visits and behaved appropriately with the child, but he stopped communicating with DCFS and did not meaningfully engage in services. After failing to report for a four-year prison sentence in June 2025, he evaded law enforcement until December 2025. He did not visit the child during that period, later lost his housing, and remained incarcerated. The circuit court found him unfit on four grounds—failure to maintain reasonable interest, concern, or responsibility; failure to make reasonable efforts; failure to make reasonable progress; and depravity—and terminated his parental rights after finding termination was in the child’s best interests.
The Court’s Holding
The appellate court affirmed, concluding that the unfitness finding was not against the manifest weight of the evidence. Father did not challenge the reasonable-efforts ground on appeal, which alone could support affirmance. The court nevertheless reviewed the overlapping reasonable-progress issue and held that Father failed to meaningfully engage in required services during the relevant nine-month period, had little contact with the child, lost suitable housing, and did not complete the required substance-abuse assessment or all random drug screens.
The court rejected Father’s reliance on favorable visits and housing conditions that largely preceded the relevant period, as well as his participation in self-help courses while incarcerated. Reasonable progress is judged objectively, so obstacles associated with incarceration did not excuse the lack of progress. The court also upheld the best-interests determination because the child had lived with the foster family since leaving the hospital, was attached to his caregivers, received appropriate care, and could obtain permanence through adoption. Father’s desire to preserve the relationship did not displace the statutory focus on the child’s needs.
Key Takeaways
- Any single properly proven statutory ground of parental unfitness is sufficient to sustain an unfitness determination.
- Reasonable progress is measured objectively, and incarceration-related limitations did not excuse Father’s failure to substantially fulfill his service-plan obligations.
- The child’s stable, continuous placement with foster parents willing to adopt supported the finding that termination served his best interests.
Why It Matters
The order illustrates the importance of the defined nine-month period when courts assess reasonable efforts and progress toward reunification. Positive conduct outside that period does not overcome a record showing that the parent stopped visiting, failed to engage in required services, and moved further from being able to provide care during the period under review.
It also reinforces the shift in focus after a finding of unfitness: the best-interests inquiry centers on the child’s safety, attachments, stability, and need for permanence rather than the parent’s wish to retain parental rights. The order was issued under Illinois Supreme Court Rule 23 and is nonprecedential except in the limited circumstances permitted by that rule.