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Name: In re M.B.
Case #: E053095
Court: CA Court of Appeal
District 4 DCA
Division: 2
Opinion Date: 12/12/2011

Juvenile court properly restrained mother from contacting DCFS employees where mother made credible threats against them. During the dependency proceedings, mother repeatedly yelled and cursed at employees of DCFS, and was convicted of making criminal threats for making threats against an employee. After mother again threatened to shoot the social worker, DCFS sought an injunction prohibiting mother from contacting its employees except through counsel. The juvenile court issued the injunction, and mother appealed, arguing that the juvenile court did not have the authority to issue the injunction, and there was insufficient evidence to support it. The appellate court rejected the arguments, finding that although the juvenile court lacked statutory authority to issue the injunction, it had inherent authority to prevent abuses which would undermine the proper administration of justice. The juvenile court not only had the authority but the duty to intervene. Further, there was sufficient evidence to support the injunction. There was more than ample evidence that mother posed an imminent threat to DCFS employees.