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Name: In re Madison S.
Case #: A144936
Court: CA Court of Appeal
District 1 DCA
Division: 4
Opinion Date: 08/15/2017

Substantial evidence supported the juvenile court’s jurisdictional and dispositional findings where father inflicted serious physical abuse on infant minor. The minor was injured nonaccidentally, resulting in a skull fracture and hematomas on the brain. The juvenile court determined that father had inflicted abuse on the minor. It found jurisdiction under section 300(e) and denied reunification services to father. The appellate court affirmed the findings. Father denied he was responsible for the infant minor’s injuries, but there was evidence that father made statements to mother admitting he caused the injuries. Further, the expert the juvenile court found the most credible concluded that the minor’s injuries were caused by blunt force trauma rather than from birth injuries. A second expert opined that the injuries were of a type usually caused by blunt force trauma or shaking. The appellate court declined to reweigh the evidence and credibility determinations, holding there was substantial evidence to support jurisdiction. Moreover, father’s bypass of services under subdivision (b)(5) was supported by the evidence. The issue of father’s culpability was extensively and thoughtfully explored by the juvenile court, and the court expressly found that the minor was a victim of nonaccidental injury at the hands of his father. On these facts, it is difficult to imagine how any services would have been likely to prevent reabuse.