In re Star R., 19 N.E.3d 1226

Star R., a nine-year-old girl, was adjudicated abused and neglected based on injuries to a sibling, the mother's intoxication, domestic violence in the home, and unstable housing; she was removed from the mother and placed in DCFS temporary custody.
DNA later established Donald S. (respondent) as Star’s biological father in February 2014; respondent sought to have custody returned to him but had only recently met Star and had two prior children in his care.
At disposition, Star had lived with three siblings in a safe two-parent foster home since September 2013; she is a special-education student with emotional needs and had not yet received recommended psychological testing or counseling.
The DCFS caseworker found respondent’s home appropriate but noted respondent had minimal prior contact with Star, had not been assessed for services, and there were unconfirmed reports he might use alcohol or marijuana; respondent had two brief visits with Star and cancelled/ missed some visits.
The juvenile court adjudged Star a ward and, finding insufficient information to assess family reunification at that time, placed her in the custody of a DCFS guardianship administrator pending assessments and services for respondent.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Donald)	Held
Whether the State proved by a preponderance that respondent is unable to care for Star	The court may place the child outside parental custody when necessary for the child’s best interest; removal appropriate given lack of assessments and need to protect child pending reunification efforts	Donald argued record showed a safe home, ability to parent two teens, no proof of drug/alcohol use, willingness to be assessed; no factual basis to find him unable/unfit	Court: Although State did not prove respondent unfit by preponderance, placement with DCFS was not against manifest weight because best interests favored maintaining Star in foster care until assessments and reunification steps occur

In re Brandon S., 331 Ill. App. 3d 757 (Ill. App. Ct. 2002) (dispositional orders in juvenile cases are generally final and appealable)
In re Christopher S., 364 Ill. App. 3d 76 (Ill. App. Ct. 2006) (failure to object at trial waives sufficiency-of-findings challenge; oral findings may satisfy statutory requirement)
In re Madison H., 215 Ill. 2d 364 (Ill. 2005) (oral findings can satisfy statutory requirement when they inform parties of basis for decision)
In re J.J., 327 Ill. App. 3d 70 (Ill. App. Ct. 2001) (juvenile court’s primary concern is child’s best interest; unnecessary to find parent unfit if best interests require placement with others)
In re Stilley, 66 Ill. 2d 515 (Ill. 1977) (juvenile court vested with broad discretion to serve child’s best interests)
In re Lakita B., 297 Ill. App. 3d 985 (Ill. App. Ct. 1998) (standard of proof at dispositional hearing is preponderance of the evidence)