Interpretation of Section 1(D)(M) of the Adoption Act

In In re D.L., 191 Ill. 2d 1, (2000) the supreme court interpreted section 1(D)(m) of the Adoption Act, which provides that a parent may be found unfit for: "Failure to make reasonable efforts to correct the conditions that were the basis for the removal of the child from the parent, or to make reasonable progress toward the return of the child to the parent within 12 months after an adjudication of neglected minor, abused minor or dependent minor under the Juvenile Court Act or the Juvenile Court Act of 1987." 750 ILCS 50/1(D)(m) (West 1994). The court held that section 1(D)(m) "limits the evidence that may be considered under the provision to matters concerning the parent's conduct in the 12 months following the applicable adjudication of neglect, abuse, or dependency." D.L., 2000 Ill.