In re K.D.

In this Rule 23 termination of parental rights case, the Circuit Court of Sangamon County found respondent-father unfit as to two minors, K.D. and K.L., under section 1(D)(b) of the Adoption Act for failing to maintain a reasonable degree of interest, concern, or responsibility, and terminated his parental rights following a same-day best-interests hearing. Respondent appealed both the unfitness finding and the termination decision, also seeking review of earlier adjudicatory and dispositional orders and raising procedural objections to the combined hearings.

The Fourth District affirmed across the board. It held the unfitness finding was supported by evidence that respondent never contacted the caseworker, never completed services, and never visited or inquired about either child. As to K.L., whose paternity was confirmed only shortly before trial, the court held that respondent's presence at birth and failure to pursue paternity or engage with the child even before DNA confirmation supported unfitness, and late confirmation did not excuse his inaction. The court also held it lacked jurisdiction to review the adjudicatory and dispositional orders because respondent's notice of appeal was limited to the termination judgment and those earlier orders were not timely appealed. Finally, the court rejected challenges to judicial notice of prior testimony and to holding both hearings on the same day, finding these arguments forfeited and, alternatively, meritless under the Juvenile Court Act and existing case law.

The decision reinforces standard practice regarding forfeiture, appellate jurisdiction over dispositional orders under Rule 303(a), and procedural flexibility in combining termination hearings, making it a useful reference for practitioners litigating parental fitness and termination timelines.