In re J.S., 977 N.E.2d 879

Mother locked J.S. out of the home and refused to allow him to return, leading to DCFS taking temporary custody in June 2011.
Petition alleged neglect due to lack of care, injurious environment, and substantial risk of injury under the Juvenile Court Act; mother refused to create a care plan or engage in services.
TT YC crisis worker Holman repeatedly intervened, placed J.S. in Shelter, and attempted to coordinate reunification, but mother remained unwilling to have him return home.
J.S. had extensive behavioral and mental health history, including suspensions, expulsions, hospitalizations, and therapy throughout childhood and adolescence.
The DCFS team discussed potential placement options and services; mother declined significant offered services, contributing to DCFS seeking custody.
Trial court adjudicated J.S. neglected for lack of care and later placed him in DCFS custody; mother appeals arguing dependency rather than neglect.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether neglect finding was against manifest weight.	State contends lack of care supports neglect.	Mother argues J.S. is dependent due to behavioral/mental health issues and not neglected.	Neglect affirmed; not against manifest weight.

In re Diamond M., 2011 IL App (1st) 111184 (2011) (great deference to trial court; neglect finding upheld on the record)
In re Christina M., 333 Ill. App. 3d 1030 (2002) (neglect sustaining despite argument for dependency when parent failed to facilitate care)
In re L.H., 384 Ill. App. 3d 836 (2008) (lockout by parent can constitute neglect absent danger to others)
In re Christopher S., 364 Ill. App. 3d 76 (2006) (comparison of neglect vs. dependency in context of home environment and care planning)