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Name: In re A.C.
Case #: G040540
Court: CA Court of Appeal
District 4 DCA
Division: 3
Opinion Date: 12/22/2008

The time limits for reunification services did not begin running until the minors were removed from both parents. The minors were originally detained from their mother’s home in April, 2006, and placed with the previously noncustodial father. In September, 2007, the minors were again detained on a 387 petition. Parents received reunification services following the second detention. At a review hearing held in June, 2008, the minors contended that parents had already received more than two years of services, and it was therefore inappropriate to conduct a six-month review in June, 2008 and to continue services. The appellate court rejected the argument and affirmed. The trial court properly found that the parents were entitled to additional services. The time limits for reunification services start to run when a child is removed from all parental custody. The clock does not start running when a child is placed back with the formerly noncustodial parent pursuant to section 361.2. The court also held that there was sufficient evidence to support the finding that there was a substantial probability of return of the minors within six months.