In re Adoption of J.J., 2019 IL App (4th) 190426-U

1. Case citation and parties
- In re Adoption of J.J., No. 4‑19‑0426 (Ill. App. Ct. 4th Dist. Nov. 15, 2019) (Rule 23 order).
- Petitioners/Appellees: Jodi D. (mother) and Jack D. (stepfather/adoptive petitioners).
- Respondent/Appellant: John J. (biological father).

2. Key legal issues
- Whether respondent was an unfit parent under the Adoption Act (ground: failure to maintain a reasonable degree of interest, concern, or responsibility for the child for a period in excess of two years; abandonment also alleged).
- Whether termination of parental rights was in the minors’ best interests.
- Standard of review: manifest-weight review of trial court’s factual findings based on clear-and-convincing evidence.

3. Holding/outcome
- The Fourth District affirmed the trial court’s rulings: respondent was unfit and termination of his parental rights was in the children’s best interests.

4. Significant legal reasoning (summary)
- The trial court found petitioners met their burden by clear and convincing evidence that respondent failed to maintain a reasonable degree of interest, concern, or responsibility. The appellate court concluded those findings were not against the manifest weight of the evidence.
- Key evidentiary facts: respondent had not seen one child since 2013 and the other only once since 2013; he provided no financial or material support; he did not send letters/cards or gifts; he failed to complete the required parenting class; he had multiple incarcerations (2013–2018) and criminal convictions; his documented efforts to reestablish contact were minimal (one motion filed in 2017 while incarcerated, limited school visit, and claimed attempts via relatives).
- The court weighed respondent’s explanations (incarceration, alleged obstruction by the mother, and limited legal sophistication) and found them insufficient to overcome the pattern of prolonged noncontact and lack of demonstrated responsibility. In short, episodic or ineffective attempts did not negate an extended period of non‑involvement.
- On best interests, the court emphasized stability and continuity with the petitioners (mother and stepfather), the children’s living situation and emotional needs, and respondent’s instability.

5. Practice implications
- Documented, sustained efforts to communicate, provide support, and seek custody/visitation (with proof of service and follow‑up) are critical to defend parental fitness.
- Periods of incarceration do not automatically excuse prolonged noncontact; courts look to efforts during available periods and overall pattern.
- For petitioners, compile chronological proof of non‑contact/support, failed attempts by the parent, and evidence of a stable, nurturing home to support both unfitness and best‑interests findings.
- Ensure records of parenting‑class compliance, filings, service, and communications are in the record; absence of such proof is damaging to the parent seeking to avoid termination.