Illinois Appellate Court
Civil Court
Termination of Parental Rights
Court adjudicated minor an abused and neglected minor, and found her biological parents unfit and terminated their parental rights. Mother was found unfit based on reasonable progress and reasonable degree of interest provisions, but not based on mental disability provision. Court found father unfit based on all grounds. Overwhelming evidence supported court's findings. The ADA does not provide a defense in parental termination proceedings as they are not programs, services, or activities within the purview of ADA. (HOFFMAN and CUNNINGHAM, concurring.)