The court continued the case until the dispositional hearing on March 29, 2000. At the dispositional hearing, the Guardian ad litem and the Deputy Juvenile Officer recommended that no reasonable efforts be made to reunify A.H. with appellant. The court then made an oral finding that A.H. had been subjected to a severe act of physical abuse, and consequently, pursuant to section 211.183, a determination of reasonable efforts to reunify A.H. with appellant would not be required. The review of juvenile proceedings is analogous to review of court-tried cases. The trial court's order is sustained unless no substantial evidence supports it, it is against the weight of the evidence, or it erroneously declares or applies the law.
Appellate courts defer to the trial court on issues of fact and the credibility of witnesses.
Id. Appellant raises two points on appeal. In her first point, appellant argues the trial court erred in failing to make specific findings in the dispositional order that include a determination of reasonable efforts. Reasonable efforts are not required if the child was removed on an emergency basis. In In the Interest of E.S., the court held that the juvenile court must follow all the requirements of section 211.183, even when the child was removed on an emergency basis. In the Interest of E.S., however, was decided before the 1998 amendment to section 211.183.