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Name: In re Alvin R., Jr.
Case #: B160567
Court: CA Court of Appeal
District 2 DCA
Division: 4
Opinion Date: 05/20/2003
Subsequent History: None
Summary

Reversal was required where there was insufficient evidence to support the trial court’s conclusion that reasonable services had been provided to father. The key to the reunification plan was that father and minor participate in conjoint counseling after father received eight sessions of individual counseling. The minor was refusing to return to his father, and it is unlikely that this situation would improve without conjoint counseling. DCFS provided no counseling for father, so no conjoint counseling ever occurred. After the trial court modified its order and allowed conjoint counseling without the predicate individual counseling, DCFS still failed to make that counseling available. The resulting delay effectively precluded any meaningful visitation between father and the minor during the reunification period, and therefore the court erred when it found that reasonable services had been offered. Where the minor expressed fear of his father and did not want to live with him, there was sufficient evidence to support the court’s order that his return to the father would create a substantial risk of detriment to his emotional well-being.