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Name: In re Jasmine S.
Case #: B194714
Court: CA Court of Appeal
District 2 DCA
Division: 5
Opinion Date: 07/25/2007

Disqualification of separate unit for concurrent representation of two siblings was improper where there was no actual conflict of interest. This is another one of the appeals brought by the Children’s Center of Los Angeles (CLC) from juvenile court orders disqualifying the CLC from representing children in dependency proceedings because of conflicts of interests. The CLC has created three separate units to provide legal representation to multiple clients who have conflicts of interest. In this case, two minors were represented by two separate units of the CLC. The juvenile court disqualified the CLC, questioning the integrity of the ethical walls between the units and the “appearance” of a conflict. The appellate court reversed the order, finding that an attorney representing multiple siblings in a dependency proceeding may only be disqualified if the siblings have an actual present conflict of interest. A mere potential of conflict does not warrant disqualification. The juvenile court here abused its discretion because it applied the wrong legal standard, and there was no substantial evidence of an actual conflict, even if the separate CLC units were treated as a single firm for conflict purposes. [Editor’s note: Review was recently granted on this issue in In re Charlisse C. (S152822/B194568).]