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Name: In re Jaden E.
Case #: A139117
Court: CA Court of Appeal
District 1 DCA
Division: 4
Opinion Date: 09/19/2014
Summary

When minor is placed with previously noncustodial parent pursuant to section 361.2, a reasonable services finding need not be made at subsequent review hearings. Minor was placed with his previously noncustodial parent pursuant to section 361.2 following removal from mother’s custody. Reunification services were ordered for mother. Six months later, mother’s services were terminated. On appeal, mother argued that the juvenile court’s finding that reasonable services had been offered was erroneous, and that she was entitled to another six months of services. The appellate court rejected that contention, finding that a reasonable services finding need not be made at a hearing monitoring a dispositional placement with a previously noncustodial parent. The court further found that the termination of services order was entirely proper, as mother maintained she did not need any services and remained oblivious to the impact of her behavior on her son.