In re McMillon

How later courts describe this case

• holding that "[w]here there is competent evidence to support the court's findings, the admission of incompetent evidence is not prejudicial"
• stating that "[w]illfulness is established when the respondent had the ability to show reasonable progress, but was unwilling to make the effort"
• "[U]nder such circumstances, the trial court need not make detailed findings as to the amount that would be `reasonable' to expect from respondent."
• "In a bench trial, the court is presumed to disregard incompetent evidence."