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Name: In re B.H.
Case #: E063278
Court: CA Court of Appeal
District 4 DCA
Division: 2
Opinion Date: 01/06/2016

Juvenile court properly bypassed father for services where he failed to reunify with a half-sibling of the minor, even though he was not the custodial parent of the sibling. At the disposition hearing in a dependency action, father was denied reunification services pursuant to Welfare and Institutions Code section 361.5, subdivision (b)(10) because he had failed to reunify with the minor’s half-sibling. On appeal, father argued that the court erred because he was the noncustodial parent at the time the child’s half sibling was removed. The appellate court rejected the argument, finding that section 361.5(b)(10) applies to a noncustodial parent. The Legislature did not intend to limit the statute’s application only to custodial parents.