Prior termination of parental rights need not have occurred in California in order to bypass reunification services under section 361.5, subdivision (b)(10). The juvenile court denied reunification services to mother under 361.5 (b)(10), as her parental rights to a sibling had been previously severed. Mother petitioned for relief, challenging the bypass because her parental rights to the sibling had been terminated in Texas. Mother relied on Melissa R. v. Superior Court (2012) 207 Cal.App.4th 816, which held that section 361.5, subdivision (b)(10), authorizing bypass of services where services have been terminated due to a prior failure to reunify, applies by its plain terms to only a termination of services in a prior California dependency proceeding. The appellate court rejected mother’s argument. Section 361.5(b)(10) contains no language specifying the severance of parental rights to a sibling must be pursuant to a California Welfare and Institutions Code provision. Had the Legislature intended to limit subdivision (b)(10) to cases where parental rights have been terminated in California, it could easily have done so. Since ample evidence supported the juvenile court’s findings that mother had not made a reasonable effort to treat the problems leading to the severance of her parental rights, the petition for writ was denied.