Walk v. The Illinois Department of Children and Family Services 

"Close confinement" conduct which is considered child abuse is dependent upon circumstances, including factors of length of time children are confined, whether children are deprived of food and water and bathroom use, purpose, and space. DCFS Policy Guide 2000.14, which has not been properly promulgated with period for public comment, is not a rule for purposes of Section 1-70 of Administrative Procedure Act, and thus cannot form basis for court's analysis of alleged abuse and neglect. Trial court improperly adopted ALJ's findings of abuse and neglect, as confinement of children with serious behavior disorders in outdoor enclosure for brief periods of time while foster parent was doing farm chores or tending to horses was not unreasonable close confinement.