## Facts

- M.A., born in 1975, was approximately 12 years old when the relevant events occurred in 1987–1988.
- After M.A. was expelled from a weekly religion class for misbehavior, M.A.’s father used confinement as punishment.
- The father directed M.A. to enter a dog cage used for the family’s German shepherd (approximately three feet by four feet).
- The father placed the cage between a metal beam and shelves in the basement, restricting M.A.’s ability to leave.
- During confinement, M.A. was not permitted to leave the cage to use the restroom.
- M.A. was confined at least weekly for about two hours (during the time of the religion class) and at least once on a Saturday; the parties disputed whether confinement occurred more often or for longer periods.
- After M.A. disclosed the punishment to school personnel, authorities investigated and M.A. was taken into protective custody in January 1988.
- A juvenile commissioner held a hearing and found that M.A. could return home only under juvenile-officer supervision because M.A. had not received “proper care.”
- The circuit court adopted the commissioner’s findings, and the parents appealed.

## Issues

1. Whether repeated confinement of a preteen child in a dog cage under restrictive conditions constitutes a lack of “proper care” under Missouri juvenile law.
2. Whether the evidence was sufficient to support the trial court’s finding and the order permitting return home only under juvenile-officer supervision.

## Decision

- The Missouri Court of Appeals affirmed the circuit court’s order.
- The court held that the evidence supported a finding that M.A. lacked “proper care” based on the nature and repetition of the confinement.
- The court upheld the disposition allowing M.A. to return home subject to supervision by a juvenile officer.

## Legal Principles

- A child may be found in need of court intervention when parental acts or omissions constitute a lack of “proper care,” including conduct framed as discipline that is unreasonable or degrading.
- Appellate review of juvenile protective findings is deferential; the reviewing court sustains the judgment if supported by substantial evidence and does not reweigh credibility.
- Juvenile dispositions may permissibly combine family reunification with state supervision when necessary to protect the child’s welfare.

## Conclusion

The appellate court concluded that repeatedly confining M.A. in a dog cage under restrictive conditions was sufficient to establish a lack of proper care, and it sustained the trial court’s order returning M.A. to the home only under juvenile-officer supervision.


In re M.A., 781 S.W.2d 94 (Mo. Ct. App. 1989)