Illinois Appellate Court
Civil Court
Termination of Parental Rights
Court erred in finding Respondent father an unfit parent. State failed to prove unfitness on ground of depravity. State failed to raise rebuttable presumption of depravity, as Respondent's 3 felony convictions were entered 8 years prior to filing of motion to terminate parental rights. Certified copies of convictions, alone, are not clear and convincing proof of depravity. Court erred in finding that Respondent failed to make reasonable progress toward goal of returning minor to him, as DCFS never recommended any services for him to complete upon which his progress could be measured. (HUDSON and BURKE, concurring.)