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Name: In re J.W.
Case #: B287940
Court: CA Court of Appeal
District 2 DCA
Division: 6
Opinion Date: 08/16/2018

Court affirmed holding that minor with Reactive Attachment Disorder (RAD) was likely to be adopted. During dependency jurisdiction, the minor had 12 separate placements, including an out of state placement with relatives and two placements in a therapeutic setting to evaluate and stabilize him. He was bonded to his fost-adopt parents who had cared for him for 10 months. His diagnosis was ADHD, anxiety, and RAD. At the permanency plan hearing, the trial court found him “specifically adoptable” and terminated parental rights. On appeal, mother argued that the finding that the minor was likely to be adopted was not supported by the evidence, because his behavioral problems made him unadoptable. The appellate court rejected the argument and affirmed the orders. After the court terminated mother’s contact with the minor his aggression decreased. The fost-adopt parents were able to successfully resolve many of his behavioral problems. The minor’s social worker testified that the minor had become a “different child” and that the prospective adoptive parents were meeting his behavioral and emotional needs. The trial court reasonably concluded that the minor was likely to be adopted within a reasonable time by these parents or another family. The court rejected the notion that a child suffering from RAD is unadoptable.