Skip to content
Name: In re Aaron S.
Case #: H040684
Court: CA Court of Appeal
District 6 DCA
Opinion Date: 03/26/2015

The court may terminate jurisdiction for a minor who makes only minimal efforts to participate in an independent living case plan. Aaron was a dependent of the court beginning at age 16. At age 18, he failed to enroll in college, was unemployed, and refused offers of job search assistance from the Department. The Department recommended termination of jurisdiction and the court followed that recommendation. On appeal, Aaron argued that the juvenile court abused its discretion in finding that he was not participating in his transitional independent living case plan. He argued that his unsuccessful attempts to enroll in college and find a job should have been deemed compliance with section 11403, subdivision (b)(2) and (3), respectively. The appellate court rejected these arguments, finding that the statute requires actual enrollment in college or employment, not just attempts to apply. The court also rejected Aaron’s argument that the Department failed to provide a 90-day transition plan. Even if the argument was not forfeited by Aaron’s failure to raise it below, termination without proof of a 90-day plan was harmless here because information was provided to Aaron which would have been included in the transition plan.