In re Jacorey S., 980 N.E.2d 91

Andre S. and Ericka M. are parents of Jacorey and Jakylah; twins adjudicated neglected and removed from home; DCFS provided services but progress was inconsistent; Andre is the biological father of the twins as of Feb 25, 2010; three nine-month periods post-adjudication assessed for progress toward reunification; trial court terminated parental rights and appointed guardian with right to consent to adoption; on appeal, court affirmed unfitness under Adoption Act sections 1(D)(m) and 1(D)(b).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Andre made reasonable progress toward reunification under 1(D)(m).	State argues Andre failed to show progress in all three nine-month periods.	Andre contends progress occurred given limited periods of therapy and other caregiving.	Affirmed
Whether Andre maintained a reasonable degree of interest, concern or responsibility under 1(D)(b).	State argues lack of consistent therapy and visits shows insufficient interest.	Andre claims some caregiving and services show interest.	Affirmed
Whether the nine-month progress standard was properly applied given delayed paternity finding.	State contends objective standard supports unfitness regardless of late paternity.	Andre contends lack of initial paternity knowledge affected progress.	Affirmed

In re Konstantinos H., 387 Ill. App. 3d 192 (2008) (establishes bifurcated proof for unfitness and standard of review)
In re Tiffany M., 353 Ill. App. 3d 883 (2004) (defines nine-month progress framework)
In re Daphnie E., 368 Ill. App. 3d 1052 (2006) (distinguishes reasonable efforts vs. progress)
In re B.W., 309 Ill. App. 3d 493 (1999) (objective standard for reasonable progress when unaware of birth)
In re R.L., 352 Ill. App. 3d 985 (2004) (notes separation of reasonable efforts and progress as grounds)
In re C.E., 406 Ill. App. 3d 97 (2010) (addresses elements of 1(D)(b) and consideration of conduct)