Where juvenile court expressly declined to issue exit orders following termination of jurisdiction, its post termination orders regarding healthcare decisions were vacated, and the original family court orders prevailed. A dependency petition was filed, and jurisdiction assumed, after the family court entered a final judgment awarding Todd T. sole legal authority to make healthcare decisions for his daughter, Anna T. When the juvenile court terminated jurisdiction a year later, it expressly declined to issue an exit order under section 362.4 reverting back to the original family law decision. However, the court ordered Anna to continue in treatment with a therapist chosen by mother and paid for by Todd, until the therapist determined that a change would not interfere with Anna’s treatment. It also prohibited Todd from returning Anna to two healthcare providers who had previously seen her. Todd appealed the healthcare orders, arguing among other things an improper delegation of authority to Anna’s therapist. The appellate court did not reach the issues raised by Todd. The appellate court found that the juvenile court orders had no continuing effect after the juvenile court terminated jurisdiction. Any ongoing issues regarding Todd’s authority to make healthcare decisions were properly addressed in the family court. The juvenile court could have issued an exit order when it dismissed jurisdiction, but it declined to do so. Therefore, the orders purporting to modify the family court’s final judgment granting Todd the authority to make all healthcare decisions for Anna were vacated.

The full opinion is available on the court’s website here: https://www.courts.ca.gov/opinions/documents/B299987.PDF