In the Interest of C.C., 2022 IL App (1st) 211232-U

Neighbor found the infant alone in a stroller; police found the mother passed out at the doorway and the father unresponsive to the child, prompting a DCFS investigation and temporary removal.
Mother admitted substance-abuse problems, completed inpatient and outpatient treatment, and the child was reunified with parents under an order of protective supervision requiring random drug tests.
Father repeatedly refused to cooperate with services and drug testing; caseworkers described him as “obstinate” and at times difficult or sleepy during visits.
Mother later had multiple inconsistent positive drug tests: urine positives for methamphetamine and low-level fentanyl/norfentanyl, and a hair-follicle positive for methamphetamine but negative for amphetamines despite her prescribed Adderall.
Based on the mother’s positive tests (and speculative explanations for them) plus the father’s continued refusal to comply with services, the trial court vacated protective supervision, found both parents unable to care for the child, and placed the minor with DCFS.
Mother appealed arguing (1) the trial court failed to make adequate written/oral factual findings under section 2-27(1), and (2) the removal was against the manifest weight of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court made the required written/oral factual findings under 705 ILCS 405/2-27(1)	Mother: court’s written order was a standard form and record lacked specific factual basis; findings insufficient	DCFS/GAL: oral findings on the record (and references to prior hearings/transcripts) supply the required factual basis; forfeiture not applied to child-welfare context	Court: Affirmed. Transcripts contained explicit oral findings (mother’s positive tests + father’s refusal), satisfying the writing requirement.
Whether removal was against the manifest weight of the evidence	Mother: test results were inconsistent and could be false positives from prescribed Adderall; child was well cared for—court should have left child at home	DCFS/GAL: hair and urine positives and father’s ongoing noncompliance justified removal; court not required to wait for a full relapse	Court: Affirmed. Credibility choice to credit positive tests and father’s obstinacy was not manifest error; removal permissible.

In re Madison H., 215 Ill. 2d 364 (Ill. 2005) (oral findings on the record can satisfy section 2-27(1) if sufficiently explicit)
In re Aaron R., 387 Ill. App. 3d 1130 (Ill. App. Ct. 2009) (de novo review on whether statutory factual findings were made)
Haudrich v. Howmedica, Inc., 169 Ill. 2d 525 (Ill. 1996) (forfeiture rule for failures to object at trial)
In re Michael H., 392 Ill. App. 3d 965 (Ill. App. Ct. 2009) (forfeiture is a limitation on the parties, not the court)
In re Edward T., 343 Ill. App. 3d 778 (Ill. App. Ct. 2003) (court may consider behavior of others in the home when deciding child placement)
In re S.S., 313 Ill. App. 3d 121 (Ill. App. Ct. 2000) (importance of conduct of household members in custody questions)
People v. Morgan, 212 Ill. 2d 148 (Ill. 2004) (definition of manifest error standard)
In re N.B., 191 Ill. 2d 338 (Ill. 2000) (standard for manifest weight review)
In re R.C., 195 Ill. 2d 291 (Ill. 2001) (policy preference that children remain in parental custody when feasible)