In re Adoption of Blake B., 2022 IL App (5th) 220154-U

1) Case citation and parties
- In re Adoption of Blake B., 2022 IL App (5th) 220154-U (Ill. App. Ct. 5th Dist. July 20, 2022) (Rule 23 order, non‑precedential).
- Petitioners/Appellees: Ramona R. & Robert G. (maternal grandmother and her husband).
- Respondents/Appellants: Aymara R.B. (mother) and James A.B. (father). Appeal by mother Aymara R.B.

2) Key legal issues
- Whether the trial court erred in finding the mother unfit under the Illinois Adoption Act (750 ILCS 50/1(D)) — including grounds of failure to maintain reasonable interest/concern/responsibility, failure to visit/communicate for 12+ months, failure to plan for the child, and habitual drug/alcohol addiction.
- Whether terminating parental rights and approving adoption by petitioners was against the child’s best interests.
- Whether there were any meritorious issues for appeal (Anders counsel motion).

3) Holding/outcome
- Appellate court affirmed. Counsel’s Anders motion granted; counsel allowed to withdraw. The circuit court’s findings of parental unfitness and that adoption by petitioners was in the child’s best interest were upheld.

4) Significant legal reasoning
- Standard: parental unfitness must be proved by clear and convincing evidence. The court may find any one statutory ground sufficient.
- The record showed virtually no contact between mother and child from Dec. 2016 until after the adoption petition (years of non‑contact, no cards/gifts/support except limited payments), missed/failed supervised visits, failure to engage in offered virtual parenting time, and evidence of drug use (including appearing under the influence during a Zoom visit and recent felony drug charge). Trial testimony established the child’s significant medical/developmental needs (Turner syndrome, speech/occupational therapy, feeding concerns) and the petitioners’ ongoing care and stability.
- Applying Syck and other precedents, the court emphasized examining parental efforts rather than success; here the mother’s lack of effort supported unfitness findings. The court also found termination in the child’s best interest given the child’s needs, lack of bond with mother, and stability with petitioners.

5) Practice implications for family attorneys
- One statutory ground proved by clear and convincing evidence can sustain an unfitness finding — focus proof on any dispositive statutory element (e.g., 12+ months’ non‑contact).
- Document offers of visitation and the parent’s responses; contemporaneous records, GAL testimony, and demonstration of the custodial caregivers’ continuous involvement are persuasive.
- Evidence of substance abuse, criminal charges, and impaired parenting episodes (including virtual appearances) is highly probative.
- When representing parents on appeal, ensure potential issues meet arguable merit standards under Anders; appellate courts will affirm well‑supported fitness/best‑interest findings and permit withdrawal if no non‑frivolous points exist.