A parent may appeal only the reasonable services component of the juvenile court’s order made at the six month review hearing. Following a finding of physical abuse by mother, visitation between mother and minor was ordered to occur in a therapeutic setting. Four months later, the minor began participating in therapy with the goal of eventually working towards therapeutic visitation with Mother. At the six-month review hearing, Mother argued she had not been provided with reasonable services because the Agency had made little effort to comply with the therapeutic visitation. The juvenile court found reasonable services had been provided and ordered Mother continue to receive services. Mother appealed and the reviewing court affirmed. Mother may challenge only the reasonable services finding made at the hearing. A parent is aggrieved by a reasonable services finding because an erroneous finding could impair the parent’s ability to get further services and reunify. The proper avenue to challenge the provision of reasonable services finding is to appeal the order in which it was made. Here, even though Mother has already received an extension of services, a previous finding that the Agency failed to provide reasonable services could allow her to argue for a further extension of services and against the termination of her parental rights and thus, she can challenge that component of the court’s order on appeal. However, since substantial evidence supported the finding as the Agency made reasonable efforts to facilitate the therapeutic visits, the orders were affirmed.

The full opinion is available on the court’s website here: https://www.courts.ca.gov/opinions/documents/B339164.PDF