State of Illinois v. Lakeia b.

Bloomington, Illinois, family law lawyer represented the Defendant in a parental rights termination action.

Digested by: Kent Morlan

In April 2025, the State filed a petition to terminate respondent's parental rights to the minors. The State alleged respondent was an unfit parent in that she failed to make reasonable progress toward the return of the minors to her care during a nine-month period following their September 5, 2023, adjudications of neglect, namely, July 1, 2024, to April 1, 2025 (750 ILCS 50/1(D)(m)(ii) (West 2024)). The State further alleged it was in the minors' best interests to terminate respondent's parental rights and appoint the Illinois Department of Children and Family Services (DCFS) as guardian, with the power to consent to adoption.

the evidence showed the minors came into DCFS care due to domestic violence between their parents. It was recommended respondent and the minors' father complete domestic violence and parenting programs. Unlike the minors' father, respondent engaged in and completed the recommended programs. Respondent was advised not to continue a relationship with the minors' father due to his lack of engagement in services and, after concerns of an ongoing relationship persisted, was explicitly ordered to have no contact with him. Despite this, respondent maintained a relationship with the minors' father, as evidenced by the phone calls in late December 2024. She then repeatedly lied to the minors' caseworker about the contact and did not take accountability for her actions. This resulted in additional recommendations for domestic violence and parenting services and the requirement of supervision during visits. As the trial court found, respondent's actions showed she had not learned the necessary skills and knowledge from completing the domestic violence and parenting programs to safely parent the minors and, therefore, required additional services, meaning it was unlikely the minors would be returned to her care in the near future. Given the information gleaned from the evidence presented, we conclude the unfitness finding based on respondent's failure to make reasonable progress toward the return of the minors is not against the manifest weight of the evidence.

When considering whether termination of parental rights would be in a child's best interest, the trial court must consider several statutory factors within the context of the child's age and developmental needs. See 705 ILCS 405/1-3(4.05) (West 2024). The focus is on the child, and the parent's interest in maintaining the parent-child relationship must yield to the child's interest in a stable, loving home life. D.T., 212 Ill.2d at 364.

Parental rights terminated.

Affirmed.