In re Adoption of Jaxon R., 2023 IL App (5th) 230452-U

- Case citation and parties
In re Adoption of Jaxon R., No. 5-23-0452, 2023 IL App (5th) 230452‑U (Ill. App. Ct. Nov. 16, 2023) (Rule 23 order). Petitioner/Appellee: Sabrina J. Moss (great‑grandmother and long‑time guardian). Respondent/Appellant: Charles R. (natural father).

- Key legal issues
1. Whether the trial court’s finding that Charles was an unfit parent was against the manifest weight of the evidence (grounds alleged: abandonment, failure to maintain a reasonable degree of interest/concern/responsibility, and desertion).
2. Whether terminating Charles’s parental rights and allowing adoption by the petitioner was in the child’s best interest.
3. Properly identifying which statutory basis supported an unfitness finding.

- Holding/outcome
The appellate court affirmed the trial court’s unfitness and best‑interest findings but modified the judgment to clarify that the father was found unfit solely on the statutory ground of failure to maintain a reasonable degree of responsibility for the child.

- Significant legal reasoning (concise)
The record showed long‑term incarceration (30‑year sentence, earning 85%), sporadic and superficial contact (calls every few months, “silly” conversations, occasional letters/gifts via third parties), no financial support, failure to register on the Putative Father Registry, and prison disciplinary incidents undermining claims of responsible parenting. The child had been in petitioner’s care since infancy, with petitioner providing stability and limiting ineffective or harmful contact. The court concluded the quality and frequency of the father’s involvement were insufficient to satisfy the statutory standard of reasonable responsibility. While some facts (calls, gifts) existed, they did not negate the manifest weight of evidence supporting unfitness for that specific statutory ground. The appellate court therefore affirmed but narrowed the grounds supporting the termination.

- Practice implications for family law attorneys
- For fathers/defense: incarceration alone is not determinative; timely, documented, meaningful efforts (call logs/Securus records, letters, commissary/financial records, court filings) and registration on the Putative Father Registry are critical to preserve rights. Show custodial‑parent interference where applicable. Pursue and follow up on family‑court petitions (visitation/paternity).
- For petitioners/adopters: develop a record of long‑term caregiving, stability, and evidence that the parent’s contact lacked substance or consistency. Emphasize best‑interest factors (bonding, stability, child preference/behavior toward visits).
- Appellate note: Illinois courts may modify judgments to reflect the specific statutory ground actually supported by the evidence; Rule 23 disposition (nonprecedential) applies here.