Section 1(D)(b) is phrased in the disjunctive, meaning that any of the three elements (interest, concern, or responsibility) may be considered on its own as a basis for unfitness. In re J.B., 2014 IL App (1st) 140773, ¶ 51. Courts consider a parent's conduct in the context of the circumstances in which it occurs, including any difficulty in obtaining transportation to the child's residence, the parent's poverty, conduct of others that hinders visitation, and motivation underlying the failure to visit. In re Daphnie E., 368 Ill.App.3d at 1064.
(Internal quotation marks omitted.) In re J.B., 2014 IL App (1st) 140773, ¶ 51, 19 N.E.3d 1273. When examining allegations under subsection (b), a circuit court must focus on the parent's reasonable efforts and consider any circumstances that may have made it difficult for the parent to visit, communicate with, or otherwise show interest in the child.
Second, "[a]ssuming the parent is found unfit, the circuit court must then consider whether it is in the best interests of the children to terminate parental rights." In re J.B. , 2014 IL App (1st) 140773, ¶ 49, 386 Ill.Dec. 120, 19 N.E.3d 1273. " ‘A parent's rights may be terminated if even a single alleged ground for unfitness is supported by clear
(Internal quotation marks omitted.) In re Abdullah, 85 Ill. 2d 300, 305, 423 N.E.2d 915, 917 (1981); see also In re J.B., 2014 IL App (1st) 140773, ¶ 61, 19 N.E.3d 1273. "There is a rebuttable presumption that a parent is depraved if the parent has been criminally convicted of at least 3 felonies *** and at least one of these convictions took place within 5 years of the filing of the petition or motion seeking termination of parental rights." 750 ILCS 50/1(D)(i) (West 2016).
We do not reweigh the evidence on appeal. In re J.B, 2014 IL App (1st) 140773, ¶ 49. Nor will we reverse a finding of unfitness unless it is against the manifest weight of the evidence. In re Gwynne P., 215 Ill. 2d 340, 354 (2005).
(Internal quotation marks omitted.) In re J.B., 2014 IL App (1st) 140773, ¶ 51, 19 N.E.3d 1273.¶ 82 The trial court's unfitness determination is supported by the manifest weight of the evidence.
We give great deference to a trial court's finding of unfitness, defer to the trial court's findings of fact and credibility assessments, and do not reweigh the evidence on appeal. In re J.B., 2014 IL App (1st) 140773, ¶ 49. "Although section 1(D) of the Adoption Act sets forth numerous grounds under which a parent may be deemed 'unfit,' any one ground, properly proven, is sufficient to enter a finding of unfitness." In re Donald A.G., 221 Ill. 2d at 244. ¶ 61 As previously stated, the trial court in this case found L.S. unfit under subsections (b), (g), and (m) of section 1(D) of the Adoption Act.
We do not reweigh the evidence on appeal. In re J.B., 2014 IL App (1st) 140773, ¶ 49. We will not reverse a finding of unfitness unless it is against the manifest weight of the evidence.
We give great deference to a trial court's finding of unfitness, defer to the trial court's findings of fact and credibility assessments, and do not reweigh the evidence on appeal. In re J.B., 2014 IL App (1st) 140773, ¶ 49. "Although section 1(D) of the Adoption Act sets forth numerous grounds under which a parent may be deemed 'unfit,' any one ground, properly proven, is sufficient to enter a finding of unfitness." In re Donald A.G., 221 Ill. 2d at 244. ¶ 61 As previously stated, the trial court in this case found L.S. unfit under subsections (b), (g), and (m) of section 1(D) of the Adoption Act.
Respondent is correct that the procedure to terminate a parent's rights must comply with the requirement of procedural due process. See In re J.B., 2014 IL App (1st) 140773, ¶ 42, 386 Ill.Dec. 120, 19 N.E.3d 1273. Further, a parent may be found unfit under the Act for failure to make reasonable progress toward the return of the child.