In re D.F. et al., Minors (The People of the State of Illinois v. Lashawn F.), 208 Ill. 2d 223

Summary

The Illinois Supreme Court considered the time period for assessing a parent's reasonable efforts and reasonable progress under section 1(D)(m) of the Illinois Adoption Act in a proceeding to terminate parental rights. The court held that the nine-month assessment period applies to both grounds and begins on the date of the adjudication of neglect, abuse, or dependency, rather than the later dispositional order.

Holdings

1. The nine-month evaluation period in section 1(D)(m), as amended by Public Act 91-373, applies to both the reasonable-efforts ground and the reasonable-progress ground.
2. The nine-month period begins on the date the trial court enters its order adjudicating the minor abused, neglected, or dependent, not on the date of the dispositional order.
3. The unfitness finding was not against the manifest weight of the evidence because respondent did not challenge the sufficiency of the evidence from the legally relevant nine-month period.

Questions Presented

1. Whether the nine-month evaluation period in section 1(D)(m) of the Adoption Act applies to both the reasonable-efforts and reasonable-progress grounds of parental unfitness.
2. Whether the nine-month evaluation period begins on the date of the adjudication of abuse, neglect, or dependency or on the date of the subsequent dispositional order.
3. Whether the circuit court's finding of unfitness was against the manifest weight of the evidence.

Disposition

affirmed