In Re RR, 949 N.E.2d 209

R.R. (born Feb. 19, 2010) sustained brain injuries including a skull fracture; initial tests later revealed injuries not all evident at first.
Medical records showed Feb. 27, 2010 brain hemorrhages and March 25, 2010 new brain injuries; a March 26, 2010 skeletal survey disclosed a skull fracture.
The State filed juvenile petitions on April 5, 2010 alleging neglect due to an injurious environment related to R.R.'s injuries and parental histories.
Dr. Channing Petrak concluded the March 25 injuries were not birth-related and were inflicted abusive head trauma, and that the skull fracture was inflicted.
Anna R. denied causing injuries; the guardian ad litem could not determine intent; adjudicatory hearing occurred June 10, 2010.
At dispositional hearing, caseworker Walker recommended Anna R. be found fit, while the court ultimately found the minors neglected and Anna R. unfit, with DCFS guardianship ordering

Issue	Plaintiff's Argument	Defendant's Argument	Held
Neglect based on Petrak report admissibility	State	Anna R. challenged Petrak report's admissibility	Neglect supported; report admissible
Unfitness despite recommended fitness	State contends unfitness supported by injuries and ongoing services	Anna R. argues fitness given cooperation and recommendations	Unfitness not against manifest weight; ongoing services justified

In re Arthur H., 212 Ill.2d 441 (Ill. 2004) (definitional framework of neglect and injurious environment; expert reliance on medical records allowed)
In re J.C., 396 Ill.App.3d 1050 (Ill. App. 2009) (adjudicatory focus on neglect; admissibility of evidence relevant to neglect)
Moran v. Erickson, 297 Ill.App.3d 342 (Ill. App. 1998) (medical opinion may rely on patient information and records)
Mesick v. Johnson, 141 Ill.App.3d 195 (Ill. App. 1986) (expert testimony permissible when based on data reasonably relied upon)
People v. Ramsey, 205 Ill.2d 287 (Ill. 2002) (contemporary admissibility and forfeiture principles for evidence)