In re O.T.

2026 IL App (1st) 250610-U
SECOND DIVISION
October 13, 2026
No. 1-25-0610
NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the
limited circumstances allowed under Rule 23(e)(1).
IN THE
APPELLATE COURT OF ILLINOIS
FIRST JUDICIAL DISTRICT
In re O.T., M.T., Z.K., Minors,
Respondents-Appellees
(THE PEOPLE OF THE STATE OF ILLINOIS,
Petitioner-Appellee,
v.
ALLISEN B.,
Respondent-Appellant).
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Appeal from the Circuit Court
of Cook County.
Nos. 2024 JA 00873
2024 JA 00874
2024 JA 00875
Honorable Peter J. Vilkelis,
Judge, presiding.
PRESIDING JUSTICE D.B. WALKER delivered the judgment of the court.
Justices McBride and Van Tine concurred in the judgment.
ORDER
¶ 1 Held: Mother-respondent’s contention that the trial court erred in naming her a perpetrator
of neglect is moot. The trial court’s finding that the mother-respondent was unable
to protect the minors was not against the manifest weight of the evidence. The trial
court’s factual basis for its dispositional finding did not comply with the
requirements of the Juvenile Court Act. We remand for further proceedings.
¶ 2 Following a hearing, the trial court adjudged one-year-old O.T., two-year-old M.T., and
four-year-old Z.K. wards of the court, finding the children neglected due to an injurious

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environment and abused due to the substantial risk of future injury. On appeal, respondent Allisen
B., the mother of the children initially contends that the court erred in finding Allisen a
“perpetrator” of neglect, arguing that she committed no neglectful or abusive act or omission. In
the alternative, Allisen makes two contentions of error: (i) the State failed to prove that Allisen
was unable to parent the children at the time of the dispositional hearing, and (ii) the court failed
to explain the basis for its dispositional findings pursuant to section 2-27(1) of the Juvenile Court
Act of 1987 (Act) (705 ILCS 405/2-27(1) (West 2024)), warranting remand. For the following
reasons, we remand this cause for further proceedings.
¶ 3 BACKGROUND
¶ 4 On November 26, 2024, the State filed petitions for the adjudication of wardship for
respondent Allisen B.’s three children, O.T. (born October 30, 2023), M.T. (born May 28, 2022),
and Z.K. (born June 22, 2020). The State alleged that the minors were neglected due to an injurious
environment and abused. The State’s petitions alleged the following. The children’s parents,
respondent Allisen B. and the putative father (Alexander T.), had a prior report for risk of harm
due to neglect, and on November 19, 2024, Z.K. was diagnosed with fractures and observed with
multiple bruises. Z.K. claimed that Alexander caused the injuries and expressed fear of him.
Medical staff found Alexander’s explanation inconsistent with the injuries. Allisen confirmed it
was not the first time Alexander had harmed the children and reported a history of domestic
violence. The parents were living together during the incident, but Alexander was incarcerated at
the time of the petition and paternity was unconfirmed. The State also filed a motion for temporary
custody to be granted to the Department of Children and Family Services (DCFS) Guardianship
Administrator. Finally, the State included an affidavit from a DCFS investigator stating, inter alia,
that Allisen and Alexander had an “extensive” history of domestic violence, and that DCFS had

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made reasonable efforts to provide the family with services, including “INTACT family service
and [d]omestic violence counseling,” but “they opt[ed] out of both services.”
¶ 5 The State included an affidavit from DCFS documenting its efforts. The affidavit first
recounted that Allisen reported “ongoing domestic violence” in the home while the children were
present. Allisen further reported that Alexander strangled her until she lost consciousness and that
she delayed obtaining medical treatment for Z.K.’s injury for about three hours because she feared
Alexander. She also reported that Alexander routinely yelled at the children and had kicked one
child in the ribs, but she neither sought medical attention nor reported the incident. Alexander
admitted engaging in domestic violence. The affidavit concluded that the children were at risk
with Alexander in the home and that Allisen was unable to be “a protective factor” for the children.
¶ 6 On March 4, 2025, the adjudicatory hearing began. DCFS investigator Carol Washington
testified that, in 2024, she was assigned to investigate Allisen and Alexander with respect to several
allegations concerning their children, including inadequate food, substantial risk of harm, and
substantial risk of harm due to neglect. She explained that the allegations included a “domestic”
between Allisen and Alexander, drug use, the children being left home alone, a “filthy” home
environment, and funds intended for the children’s care being used for drugs and alcohol.
Washington testified that she did not speak with Allisen or Alexander during her investigation
because she was unable to enter the home and neither parent responded to her telephone calls.
Washington added that she did have a telephone conversation on July 14, 2024, but it was with
Alexander’s sister and not with Allisen. On cross-examination, Washington conceded that all of
the allegations were “marked unfounded” except for “the injurious environment.”
¶ 7 Carlisle Brown, the Intact Family Services Supervisor with Envision Unlimited, next
testified that she had supervised the caseworker assigned to the “intact case” involving Allisen,
Alexander, and their three minor children. Brown participated in a transitional visit at the family’s

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home in August 2024 that was also attended by a DCFS investigator, Allisen, Alexander, and the
three children. According to Brown, the visit included a discussion of the program, the reason for
DCFS involvement, and the services that the agency recommended. Although Brown said that the
agency intended to provide the parents with various services, including domestic-violence
education, neither parent engaged in the offered services and the case was closed unsuccessfully
because “they *** withdrew consent for services.”
¶ 8 On cross-examination from counsel for the children, Brown conceded that she did not
personally know which parent withdrew consent. Her understanding that both parents had
withdrawn consent came from the assigned caseworker during supervision. Brown did not know
who first communicated a withdrawal of consent or who actually sent the communication.
¶ 9 On cross-examination from counsel for Allisen, Brown admitted that she met Allisen and
Alexander only once and did not have a private conversation with either parent during the visit.
Brown also acknowledged that Allisen did not describe being afraid of Alexander. Brown said
that she “believe[d]” that the initial withdrawal of consent was communicated by a text message
sent from the parties’ shared phone, but Brown did not know whether Allisen or Alexander sent
the message. Brown further stated that the caseworker subsequently spoke with both parents and
conducted an in-person visit after the text message, but Brown did not know whether those
conversations occurred separately with each parent concerning the withdrawal of consent. Brown
also agreed that, at the conclusion of the case, the case record noted no concerns regarding abuse,
neglect, or safety because no bruises or injuries had been observed at that time. In addition, Brown
acknowledged that a letter sent to the family’s home contained referrals for various community
resources but no referrals for domestic violence resources. On cross-examination from counsel
for Alexander, Brown reiterated that she did not know whether Allisen or Alexander sent the
message and that a caseworker spoke to them afterwards.

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¶ 10 Kenard Gray, a DCFS investigator, testified that, on November 19, 2024, he was assigned
to investigate allegations involving Allisen, Alexander, and their three children. The investigation
arose after their son, Z.K., was taken to the emergency room with a fractured arm and other injuries
in various stages of healing. Gray reviewed the family’s prior DCFS history noting prior
allegations of inadequate food (which was later deemed “unfounded”) and substantial risk of harm
arising from domestic violence in the home (which was “indicated” as to both parents).
¶ 11 Gray interviewed Z.K. at the hospital and observed that, in addition to a cast on his arm,
the child appeared unkempt, smelled of urine, and had bruising on his forehead and wrist. When
Gray asked Z.K. how his arm was injured, Z.K. told Gray that his father had hurt him. Z.K. also
stated that he was afraid of Alexander because Alexander had hurt him and his mother.
¶ 12 Gray then interviewed Alexander separately, who initially denied harming Z.K. and stated
that he was asleep when the injury occurred. Gray confronted him with Z.K.’s account, but
Alexander stated that Z.K. would have blamed his mother had she brought him to the hospital.
Alexander then said that Z.K. had been jumping on the bed. When Gray asked how Alexander
could have seen that if he was asleep, Alexander conceded that he had claimed to be asleep because
he did not want to “get in trouble for not watching the kids.” When asked about prior domestic-
violence incidents, Alexander explained that he had been intoxicated and that it was a mistake,
which he regretted. Gray described Alexander as becoming “agitated,” and upon learning that law
enforcement had arrived, Gray ended the interview and left the room.
¶ 13 Gray also interviewed Allisen at the hospital in the presence of the three children. Allisen
confirmed that Alexander had injured Z.K.’s arm and stated that Alexander had been awake and
yelling at the children. She reported that Alexander yells at the children “on a regular basis,” and
that “this was not the first time.” Allisen further told Gray that, when she heard Z.K. scream, she
asked what happened. Z.K. said, “[D]addy hurt me.” She also reported that Alexander said

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nothing was wrong with Z.K. and tried to “straighten” Z.K.’s arm. Finally, Gray confirmed that
he spoke with Allisen at around 4 p.m. and that Allisen said the injury had occurred at
approximately 11:30 a.m. that morning.
¶ 14 On cross-examination from counsel for Allisen, Gray stated that Allisen brought O.T. and
M.T. to the hospital at his request. Gray agreed that both children were “clean” and had no visible
physical injuries. He further acknowledged that both children underwent hospital examinations
and that their “skeletal exams were negative for signs of child abuse.” Gray also stated that Allisen
was cooperative during their conversation. Gray then recounted Allisen’s explanation that, after
the incident involving Z.K. occurred at around 11:30 a.m., Alexander prevented her from
examining Z.K. or calling for help. Gray acknowledged that Z.K. was admitted to the hospital at
approximately 1:30 p.m., but he conceded that he did not know the exact admission time. Gray
confirmed that Allisen informed him that Alexander was responsible for Z.K.’s injuries.
¶ 15 On cross-examination from counsel for Alexander, Gray agreed that Allisen did not
actually witness the incident that caused Z.K.’s arm injury; rather, she told Gray that she heard
Z.K. but did not see what happened. Gray also testified that he observed additional bruising on
Z.K. and investigated its possible origin, but at that time, Alexander was already in custody, so
Gray did not speak with him about the bruises. Gray acknowledged that he “never heard anything
from” Alexander, only hearing Allisen’s and Z.K.’s “side of the story.” Finally, Gray agreed that
it was Alexander, not Allisen, who brought Z.K. to the hospital.
¶ 16 The State then rested, and Allisen testified on her own behalf. She stated that she is the
mother of Z.K., M.T., and O.T., and that she was formerly in a relationship with Alexander. She
began dating Alexander when she was 14 and he was 17. Although the relationship was initially
good, Allisen testified that it eventually became physically and mentally abusive. Alexander
struck her with open and closed fists, and the abuse increased from occurring every few months to

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as often as several times per month. Between May and October 2024, Allisen attempted to contact
police approximately seven or more times, but Alexander sometimes took her phone, threatened
to hurt her and the children if he went to jail, and prevented her from freely leaving the home. In
July 2024, she agreed that Alexander had been arrested on suspicion of domestic violence, but she
admitted the charges were dropped because she failed to attend court. Allisen explained that, when
Alexander’s court date arrived, he “used my phone, and I couldn’t log into the Zoom.”
¶ 17 Allisen further testified that she sought assistance from Lyte Collective to obtain housing
and leave Alexander. A caseworker provided information for a domestic-violence shelter, but
Alexander found and destroyed the information. Allisen also sought separate housing through the
organization, but Alexander interfered by telling the caseworker that they no longer needed
assistance. Allisen disclosed the abuse to friends and family and, during a July 2024 DCFS
investigation, told an intact-services worker that she feared for herself and Z.K. because of
Alexander’s temper and his conduct toward Z.K. She testified that these efforts did not enable her
to leave the relationship.
¶ 18 Allisen stated that, on November 19, 2024, she ended her relationship with Alexander
“[b]ecause he broke [Z.K.’s] arm.” On that day, she heard Z.K. screaming while she was in the
bathroom. When she came out, Z.K. told her that “his daddy broke his arm.” Allisen attempted
to examine the injury, but Alexander prevented her from doing so and insisted that the arm was
not broken. Alexander ultimately took Z.K. to the hospital. Allisen explained that she wanted to
accompany Z.K., but Alexander told her that he should go because he had witnessed what
happened. At the hospital, Allisen was told that Z.K. had given the same account, namely, that
Alexander broke his arm. Allisen also disclosed the history of domestic violence and Alexander’s
conduct toward Z.K. to hospital staff.

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¶ 19 Allisen said that she reported the incident to police and sought to press charges. She also
cooperated with DCFS and detectives following the incident. She maintained that she had never
believed Alexander was capable of breaking a child’s arm, despite knowing that he had a temper
and had previously directed his anger toward Z.K.
¶ 20 On cross-examination from the State, Allisen testified that Alexander returned to the home
the day after his July 2024 arrest and continued living with her until November 19, 2024. She
acknowledged telling a police officer on November 19 that Alexander was still living with her.
She denied telling detectives that there was no history of domestic violence, maintaining that such
violence had occurred in the past. Allisen also acknowledged a prior incident in which she reported
that Alexander kicked Z.K. in the ribs but did not seek medical treatment, explaining that prior
reports to DCFS had resulted in Alexander assaulting and threatening her. Finally, Allisen testified
that Alexander ordinarily took their shared phone with him when he left the home, but on
November 19, he left it with her, allowing her to call her mother and the hospital.
¶ 21 On cross-examination from counsel for Alexander, Allisen denied that Alexander had held
several jobs while they were together, testifying that he worked at Taco Bell for approximately
one year but was not a manager and had not worked in Chicago. She maintained that the
relationship became controlling after their move from Wisconsin to Chicago in 2023 to the extent
that she was not permitted to leave the home and even their groceries were delivered. Allisen
further stated that, because she and Alexander shared a phone, he controlled her access to it and
was generally beside her when she used it. She conceded that she did not see how Z.K.’s arm was
broken but said that the child told her what had occurred. She could not recall whether Z.K.
smelled of urine when he arrived at the emergency room but noted that Alexander had dressed
Z.K. in clean clothes before taking him to the hospital. The cause was then continued for the
presentation of closing arguments to March 27, 2025.

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¶ 22 On March 27, 2025, following the parties’ arguments, the trial court announced its findings.
The court first found that the State proved by overwhelming evidence that Z.K. was physically
abused by Alexander. The evidence included Z.K.’s statements, Allisen’s account of the incident
and the history of domestic violence, Alexander’s inconsistent statements and admissions, and
medical records documenting fractures and multiple bruises. The court also found that Z.K. was
neglected due to an injurious environment and was at substantial risk of injury. As to M.T. and
O.T., the court found that, although they were not physically injured, they were exposed to the
same unsafe environment. The court stated that it was “not unsympathetic to the plight of
[Allisen]” but nevertheless found that “she is also a perpetrator of the injurious environment.” The
court named both parents as “the perpetrator of the injurious environment,” while naming
Alexander as the perpetrator of Z.K.’s physical abuse and substantial-risk-of-injury allegations.
¶ 23 The parties then agreed to proceed immediately to a dispositional hearing. DCFS
caseworker Amber Cygnor testified that the children were safe and appropriately placed together
in foster care, although Z.K. and M.T. exhibited behavioral issues requiring “trauma-based play
therapy.” She testified that Allisen had completed her integrated assessment, was engaging in
individual and domestic-violence services, was placed on a waitlist to begin parenting services in
April, and regularly engaged in supervised visitation without reported concerns. Allisen had been
referred for individual therapy but was discharged from a prior provider following two sessions
because of “communication issues.” Allisen was then referred to another provider and completed
an intake, and she was scheduled to begin services “on Tuesday.”
¶ 24 According to Cygnor, Alexander remained incarcerated, had not completed an integrated
assessment, was not receiving services due to his incarceration, and had no contact with the
children pursuant to a court order. Cygnor recommended wardship based on the history of abuse
and domestic violence as well as the children’s need for services, with a permanency goal of

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returning the children home within 12 months based upon Allisen’s cooperation with DCFS,
engagement in services, and willingness to complete her service plan.
¶ 25 On cross-examination, Cygnor agreed that she had no “concerns” with Allisen’s visits with
the children. She added that, based upon one visit that she personally observed, there was a clear
bond between Allisen and the children. Finally, Cygnor confirmed that Allisen has been
cooperating with services and that there has been good communication from her.
¶ 26 Among the exhibits that the trial court admitted into evidence was a “Permanency Hearing
Report to the Court” prepared by DCFS and filed with the court on March 4, 2025. Cygnor signed
the report and was listed as the caseworker. In that report, the section discussing the reason
“permanency cannot be achieved now” contained the following statements: “There have been
concerns raised by [Z.T.] of possible abuse (hitting all over his body) by Allisen and this should
be addressed in therapy. The scope of this hitting is unknown. [Z.T.] has also appeared fearful
when first coming into care about seeing Allisen or going home with her. Additional time should
be allotted to have a full understanding of the possible abuse or neglect that the children may have
experienced, which will be addressed in trauma-based play therapy.”
¶ 27 The trial court then announced its dispositional findings, as set forth below:
“The Court finds these minors are adjudged wards of the
court, it being in the best interest and welfare of the minors. The
Court finds the mother is unable for some reason other than financial
circumstances alone to care for, protect, train or discipline the
minors. The Court makes the same finding as to the father. The
Court also finds he’s unfit.
Reasonable efforts have been made to prevent or eliminate
the need for removal of the children from the home. Appropriate

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services aimed at family preservation and reunification have thus far
been unsuccessful. It is in the best interest of the minors to remove
them from the custody of the parents. The minors shall be placed in
the guardianship of the DCFS guardianship administrator *** with
the right to place the minors.”
The court then admonished respondents as to their appeal rights. The court also reminded
respondents that they were required to cooperate with DCFS as well as the terms of the service
plan, and that they must “correct the conditions that required the children to be in care or risk
termination of their parental rights.”
¶ 28 This appeal follows.
¶ 29 ANALYSIS
¶ 30 Allisen first contends that the trial court erred in finding that she had contributed to the
children’s injurious environment. Specifically, Allisen argues that, although “the children were
without question abused by [Alexander],” the State did not prove that she committed a neglectful
act or omission (or at a minimum, that the court failed to articulate the basis for its finding),
warranting reversal and return of the children to her care. In the alternative, Allisen makes two
contentions of error. First, she argues in the alternative that the State failed to prove that she was
unable to parent the children at the time of the dispositional hearing because the evidence at that
time established that she was cooperative with DCFS, she had engaged in domestic violence
services and therapy, and she participated in the visits she had been offered. Her second argument
in the alternative is that this matter should be remanded because the court did not provide the
factual basis underlying its dispositional findings, in violation of section 2-27(1) of the Act (705
ILCS 405/2-27(1) (West 2024)). We discuss each of Allisen’s contentions in turn.

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¶ 31 The Act comprises a two-step process the trial court must utilize to decide whether a minor
child should be removed from his or her parents’ custody and made a ward of the court. In re D.S.,
2025 IL App (1st) 241635, ¶ 32 (citing In re A.P., 2012 IL 113875 ¶ 18). The first step, the
adjudicatory hearing, involves the court solely determining whether the minor child is abused,
neglected, or dependent. 705 ILCS 405/2-18(1) (West 2024); A.P., 2012 IL 113875 ¶ 19. If the
court determines the minor child is abused, neglected, or dependent at that hearing, then the court
proceeds to the second step, a dispositional hearing, in which the court determines whether it is
consistent with the health, safety, and best interests of the minor child and the public for the minor
child to be made a ward of the court. 705 ILCS 405/2-22 (West 2024); A.P., 2012 IL 113875, ¶ 21.
In an adjudication of wardship or any proceeding brought under the Act, “the paramount
consideration is the best interests of the child.” A.P., 2012 IL 113875 ¶ 18.
¶ 32 At the adjudicatory stage, the State has the burden to prove allegations of abuse or neglect
by a preponderance of the evidence. In re Z.L., 2021 IL 126931, ¶ 61. In essence, the State need
only “establish the allegations are more probably true than not.” Id. This court will not disturb
the trial court’s finding of abuse or neglect unless it is against the manifest weight of the evidence,
i.e., “only if the opposite conclusion is clearly evident.” Id.
¶ 33 In this case, Allisen admits in her brief (as she must, because the evidence is overwhelming)
that her children were “without question” abused by Alexander. Her admission on this point
dooms her claim. At the adjudicatory phase, the trial court is only concerned with the question of
whether—and not by whom—the respondent child was abused. See 705 ILCS 405/2-18(1) (West
2024) (“At the adjudicatory hearing, the court shall first consider only the question whether the
minor is abused, neglected or dependent.”); A.P., 2012 IL 113875 ¶ 19. That the court here
apparently found that Allisen was “also a perpetrator of the injurious environment” is irrelevant to
the question of whether the children were abused. See In re Arthur H., 212 Ill. 2d 441, 467 (2004)

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(holding that “the Act instructs the circuit court during the adjudicatory hearing to determine
whether the child is neglected, and not whether the parents are neglectful”); In re S.G., 2022 IL
App (1st) 210899, ¶ 26 (noting that, at the adjudicatory hearing, “the perpetrator of the domestic
violence that resulted in a substantial risk of physical injury to the minors is largely irrelevant”);
In re R.G., 2012 IL App (1st) 120193, ¶ 35 (holding that, “who committed the alleged abuse of
A.M. is of no particular consequence in an adjudicatory hearing”). Reviewing courts do not decide
moot or abstract questions, nor do we render advisory opinions. See People ex rel. Sklodowski v.
State, 162 Ill. 2d 117, 130 (1994) (holding that this point is a “basic tenet of justiciability”).
Allisen’s concession renders this contention of error moot.
¶ 34 We now consider Allisen’s arguments in the alternative. Allisen’s first alternative
contention is that the State failed to prove that she was unable to parent the children at the time of
the dispositional hearing. She argues that, because the evidence presented at that time established
that she was cooperative with DCFS, she had engaged in domestic violence services and therapy,
and she participated in the visits she had been offered, the evidence at the dispositional hearing
“painted Allisen in a positive light” with respect to her parenting skills and engagement in services.
¶ 35 Section 2-27(1) of the Act provides in part as follows:
“If the court determines and puts in writing the factual basis
supporting the determination of whether the parents *** of a minor
adjudged a ward of the court are unfit or are unable, for some reason
other than financial circumstances alone, to care for, protect, train
or discipline the minor or are unwilling to do so, and that the health,
safety, and best interest of the minor will be jeopardized if the minor
remains in the custody of the minor’s parents *** the court may at
this hearing ***:

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* * *
(d) *** commit the minor to the Department of Children and Family
Services for care and service.” 705 ILCS 405/2-27(1) (West 2024).
Section 2-27(5)(b) further provides that custody or guardianship granted under paragraph (d) of
subsection (1) continues “until the court otherwise directs, but not after the minor reaches the age
of 21 years.” 705 ILCS 405/2-27(5)(b) (West 2024).
¶ 36 In essence, a finding at the dispositional stage that the parents of a minor are (for
nonfinancial reasons) either (1) unfit, (2) unable, or (3) unwilling to care for the minor is a
sufficient basis to remove the minor from the custody of the parents. See In re Harriett L.-B., 2016
IL App (1st) 152034, ¶ 30. Any one of the three grounds provides a sufficient basis for removal.
Id. We will uphold the court’s decision at the dispositional stage unless the court’s findings are
against the manifest weight of the evidence or the court abused its discretion by selecting an
inappropriate dispositional order. Id. Since Allisen’s alternative contention concerns the court’s
factual findings at the dispositional stage, our review is under the manifest weight standard. “A
determination will be found to be against the manifest weight of the evidence only if the opposite
conclusion is clearly evident [citation] or the determination is unreasonable, arbitrary, or not based
on the evidence presented [citation].” In re D.F., 201 Ill. 2d 476, 498 (2002). This standard
recognizes that the trial court is in the best position to assess the credibility of witnesses and weigh
the evidence, and thus we may not substitute our judgment for that of the trial court. Id.
¶ 37 Here, the dispositional hearing took place a scant four months after the State had filed its
petition. As a result, Allisen had only begun services. The record reveals that, at the time of the
dispositional hearing, Allisen had just started domestic violence services and was on the waitlist
for parenting classes scheduled to begin the following month. In addition, she had completed only
two sessions of individual therapy before being discharged due to unspecified communication

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issues. She had not yet begun therapy with the newly referred agency. Although Allisen has
completed some services and appeared to be willing to complete the entire recommended service
plan, this court has repeatedly affirmed dispositional orders removing a child from a parent’s
custody even where, as here, the parent has completed some, but not all, recommended services.
See In re A.U., 2024 IL App (1st) 231727, ¶ 79 (collecting cases). Although her visits with the
children indicated no concerns, Allisen only had supervised visits with the children and DCFS did
not recommend unsupervised visits at the time of the hearing. Finally, two of the children required
“trauma-based play therapy” to resolve their behavior issues, likely due to their home environment.
¶ 38 We note that not all of the evidence was adverse to Allisen, and this court is sympathetic
to the abuse and intimidation she suffered at the hands of Alexander. Nevertheless, we cannot
hold that the “opposite conclusion is clearly evident” or that the trial court’s findings regarding her
ability to care for her children at the time of the dispositional hearing were unreasonable, arbitrary,
or not based on the evidence presented. Consequently, its conclusion that Allisen was unable, at
that time, to parent her children was not against the manifest weight of the evidence. See D.F.,
201 Ill. 2d at 498. Accordingly, we affirm the court’s dispositional order.
¶ 39 Moreover, Allisen’s reliance upon two New York decisions and two Illinois decisions in
support of her claim does not alter our holding. With respect to the two New York decisions—
and setting aside whether our Act and New York’s Family Court Act (N.Y. Family Court
Act §§ 111 et seq. (McKinney 2026)) are sufficiently similar—both cases are factually
distinguishable. In both cases, the mother was a “nonrespondent” parent, i.e., “a parent who is not
the subject of a claim of neglect or abuse ***.” See In re R.A., 244 A.D.3d 11, 13 n.1, 239 N.Y.S3d
139, 141 n.1 (App. Div. 2025); In re Sapphire W., 237 A.D.3d 41, 44, 224 N.Y.S.3d 624, 628
(2025) (noting that the mother “was not named as a respondent”). In addition, the respondent
parent (i.e., the father) in each case was alleged to have neglected the child by committing various

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acts of domestic violence solely against the nonrespondent mother (but in the child’s presence).
See R.A., 244 A.D.3d at 13, 239 N.Y.S3d at 141; Sapphire W., 237 A.D.3d at 44, 224 N.Y.S.3d at
628. Here, by contrast, Alexander physically abused Z.K. as well as Allisen, and Allisen was
named a respondent here because she failed to protect Z.K. and her other children from
Alexander’s abuse (albeit with understandable reluctance due to Alexander’s threats of reprisal).
Here, it was her (again, arguably understandable) failure to protect her children that resulted in her
involvement in this matter. Her reliance upon R.A. and Sapphire W. is therefore misplaced.1
¶ 40 With respect to the two Illinois decisions, one did not involve (as here) the physical abuse
of a young child by the father and the mother’s failure to seek help for that child. See In re Al. S.,
2017 IL App (4th) 160737, ¶ 6 (minor diagnosed with failure to thrive due to lack of “proper or
necessary remedial care”). The other, In re K.E.S., 2018 IL App (2d) 170907, revealed that the
evidence was “uncontradicted that [the mother] had diligently complied with all aspects of her
service plan and had corrected all of the conditions that caused K.E.S. to be removed from her
care.” Id. ¶ 64. Notably, the mother had eight months to show such diligent compliance. See
id. ¶¶ 6-8 (minor placed in foster home in December 2016 and dispositional hearing ended in
August 2017). Here, Allisen had scarcely four months to show compliance, and at least one of the
recommended services had not yet begun at the time of the dispositional hearing. In any event,
our supreme court has long held that “cases involving allegations of neglect and adjudication of
wardship are sui generis, and must be decided on the basis of their unique circumstances.” Arthur
H., 212 Ill. 2d at 463 (citing In re N.B., 191 Ill. 2d 338, 346 (2000); In re Christina M., 333
1 For these same reasons, we reject Allisen’s reliance upon yet another New York state
decision in her belatedly filed reply brief. See generally, In re L.M., ___ N.Y.S.3d ___, ___, 2026
N.Y. Slip Op. 05061 (N.Y. App. Div. Aug. 20, 2026) (recounting allegation that the respondent
father “neglected the three subject children by committing acts of domestic violence against
nonrespondent mother in the children’s presence”).

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Ill.App.3d 1030, 1034 (2002)). Under the circumstances present here, we cannot hold that the
opposite conclusion reached by the court was clearly evident. Consequently, its finding was not
against the manifest weight of the evidence, and we must reject Allisen’s claim of error.
¶ 41 Finally, we direct our attention to Allisen’s second alternative claim of error: we should
remand the cause to the trial court because it did not provide the factual basis underlying its
dispositional findings pursuant to section 2-27(1) of the Act (705 ILCS 405/2-27(1) (West 2024)).
The Office of the Cook County Public Guardian (counsel for the minors-appellees) (the Public
Guardian) concedes that the court’s dispositional findings and order failed to comply with the
requirements set forth in section 2-27(1) and In re Madison H., 215 Ill. 2d 364 (2005), and it agrees
that remand is warranted. The State responds that “the record provides a sufficient factual basis”
in support of the court’s dispositional order, but it adds that, should we agree with Allisen’s
contention, this court should remand the matter for the limited purpose of allowing the court to
state the factual basis underlying the dispositional order.
¶ 42 On this point, we agree with Allisen and the Public Guardian that remand is required. As
described above, section 2-27(1) states in part that, if the trial court “determines and puts in writing
the factual basis” supporting its determination that the parents of a minor adjudged a ward of the
court are unfit, unable, or unwilling to care for the minor, the court may remove the minor from
the parents’ custody. (Emphasis added.) 705 ILCS 405/2-27(1) (West 2024). The writing
requirement in section 2-27(1) not only provides notice to the parties of the reasons forming the
basis for the child’s removal but also preserves the court’s reasoning for appellate review. See
Madison H., 215 Ill. 2d at 374. The Madison H. court, however, held that “[e]xplicit oral findings
stated during a dispositional hearing,” once transcribed, provide notice to the parties and an
opportunity for appellate review as well as written findings. Id. at 374-75.

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¶ 43 Here, however, neither the trial court’s dispositional findings nor its written order provided
the factual basis required by Madison H. As such, we must remand this cause to the trial court for
the limited purpose of allowing it to enter more specific findings with respect to its disposition,
consistent with the requirements of section 2–27(1). See id. at 378; see also In re N.W., 2026 IL
App (1st) 251675-B, ¶ 71. Consistent with the policy requiring prompt resolution of matters
involving minors, the trial court shall transmit its factual basis to the clerk of this court within 28
days of this decision. See Ill. S. Ct. R. 311 (eff. July 1, 2018); In re D.F., 208 Ill. 2d 223, 231
(2003); In re B’Yata I., 2013 IL App (2d) 130558, ¶ 41. The parties are permitted to file
supplemental briefs within 14 days of the date the trial court submits its findings.
¶ 44 CONCLUSION
¶ 45 Allisen’s contention that the trial court erred in naming her a perpetrator of neglect is moot.
The court’s finding that Allisen B. was unable to protect the minors was not against the manifest
weight of the evidence. The court’s factual basis for its dispositional finding, however, did not
comply with the Juvenile Court Act. Accordingly, we affirm the trial court’s adjudication order,
while the court’s dispositional order is remanded for further proceedings consistent with this order.
¶ 46 Affirmed in part; remanded in part for further proceedings.

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