In re S.

This Rule 23 order affirms the termination of a father's parental rights following adjudication of neglect and a combined fitness/best-interest hearing in the circuit court of Williamson County. The father appealed both the unfitness finding, based on his alleged failure to make reasonable progress toward reunification and failure to protect the minors from an injurious environment, and the subsequent best-interest determination terminating his rights.

The Fifth District affirmed on both grounds. Applying the objective standard for reasonable progress, the court held that the father's inconsistent engagement with mental health services, his failure to secure safe housing despite acknowledging the home's unsuitability, and his continued cohabitation with a domestic violence victim (his stepmother) demonstrated a lack of reasonable progress during both relevant nine-month periods. The court emphasized that personal circumstances such as homelessness or scheduling conflicts are irrelevant under this objective inquiry, and that unresolved housing issues also prevented completion of required parenting services. Because a single properly proven statutory ground suffices for unfitness, the court declined to fully analyze the injurious-environment ground but noted the same evidence would support it as well.

On best interests, the court applied the statutory factors, finding that the foster family met the children's needs for safety, stability, and permanence, while the father could not provide safe housing or address the children's needs. The court reiterated that at the best-interest stage, the child's need for permanence outweighs the parent's interest in maintaining the relationship. This decision is instructive for practitioners on how courts apply the objective reasonable-progress standard and weigh housing instability and domestic violence exposure in termination proceedings.