In re Janessa C
Key Takeaways
- 1 Completing 1 of 20 drug screens and attending 8 of 70 visits establishes failure to make reasonable progress.
- 2 Once unfitness is proven on one statutory ground, appellate courts need not address remaining grounds.
- 3 Relevant for family law attorneys handling termination of parental rights cases involving service plan noncompliance.
Summary
In June 2024, the State filed neglect and abuse petitions in Macon County regarding four minor children of Jameira C. (Mother). The minors were adjudicated neglected and made wards of the court. Mother was found dispositionally unfit in July 2024 after failing to appear and remained substantially noncompliant with her service plan over the following year. The State filed a motion to terminate parental rights in July 2025. Following fitness and best interest hearings—at which Mother again failed to appear—the circuit court terminated Mother's parental rights to all four children. Mother appealed, arguing both the unfitness finding and the best interest determination were against the manifest weight of the evidence.
The Fifth District affirmed on both issues. On unfitness, the court found the evidence overwhelming: Mother completed only 1 of 20 required drug screens, attended only 8 of 70 offered visitation sessions, failed to enroll in domestic violence services, and was unsuccessfully discharged from parenting classes. The caseworker testified that the children could not be returned in the reasonably near future. Because proof of a single statutory ground suffices, the court affirmed solely on failure to make reasonable progress and declined to address the remaining grounds.
On best interest, all four minors were thriving in familial placements committed to adoption. One child had cerebral palsy with complex medical needs being fully met by her great-grandparents. The other three were enrolled in therapies and educational programs by their maternal grandmother. Mother had not visited any of the children for months before the final hearing. The court deferred to the circuit court's credibility assessments and affirmed termination.
Key Holdings
1. A parent's completion of only 1 of 20 required drug screens, attendance at only 8 of 70 offered visits, failure to enroll in domestic violence services, and unsuccessful discharge from parenting classes constitutes clear and convincing evidence of failure to make reasonable progress toward reunification under 750 ILCS 50/1(D)(m).
2. Proof of parental unfitness on a single statutory ground is sufficient to sustain a finding of unfitness; an appellate court need not address remaining alleged grounds once one is established.
3. Once parental unfitness is established, the parent's interest in maintaining the parent-child relationship yields to the children's interest in stability, permanency, and continuity of affection, assessed under the statutory best interest factors of 705 ILCS 405/1-3(4.05).
4. Foster placements that are familial, maintain sibling contact, meet all medical and developmental needs, and are committed to adoption weigh heavily in favor of termination under the best interest analysis.