In re L.B

This appeal arose from a juvenile abuse and neglect case involving L.B. Jr. After the trial court initially adjudicated the minor abused and neglected and placed him under DCFS guardianship, the appellate court reversed and remanded for a new dispositional hearing. On remand, the trial court found the mother fit and returned the child to her custody, but again found the father, L.B. Sr., unable to parent due to his disengagement from individual therapy—his last remaining reunification service. L.B. Sr. appealed, arguing the finding was against the manifest weight of the evidence.

The appellate court affirmed. It clarified that the dispositional phase focuses on the child's health, safety, and best interests going forward, not on relitigating whether abuse or neglect occurred. Although the caseworker recommended a joint return home, she also identified unresolved issues, including the need for co-parenting discussions, unsupervised overnight visits, stable housing arrangements, and clarification of the father's income. Most critically, the father had stopped attending therapy entirely as of July 2025 and had not resumed even seven months later, contrasting with his meaningful engagement at the time of the earlier appeal. The court emphasized that completion of services is not strictly required, but meaningful participation and demonstrable progress are necessary to support reunification.

For practitioners, this decision reinforces that appellate courts give substantial deference to trial courts' dispositional findings based on live testimony, and that a parent's inconsistent or lapsed engagement in services—even without a mandate of full completion—can independently justify continued state guardianship despite a caseworker's contrary recommendation.