Julie Q. v. The Department of Children and Family Services 

Court affirmed indicated finding of DCFS that respondent mother had neglected her minor child under DCFS rule for indicated finding upon environment injurious to child. Abused and Neglected Child Reporting Act, which authorizes DCFS registry for indicated findings, was amended to remove the phrase "environment injurious" as basis for finding of neglect, due to lack of specificity in phrase. Thus, DCFS rule including environment injurious as basis exceeds scope of authority granted by Act. ALJ was not at liberty to consider evidence of prior incidents to conclude that mother had propensity to abuse alcohol and thus must have placed minor in injurious environment on date of incident in issue. (ZENOFF, concurring; BIRKETT, specially concurring.)