Mother’s boyfriend subjected the five-year old minor to extreme physical abuse. Mother failed to intervene and protect the minor, and on at least one occasion, joined in the physical abuse. Mother submitted to the allegations, and gave up her right to a contested hearing on the record. The court did not advise appellant that it could refuse to order reunification services at the time mother submitted the matter. On appeal, mother contended that the court erred when it took her submission without telling her that the court might deny her reunification services. The appellate court found no merit to the contention, and found the issue waived as appellant did not raise it below. Further, the trial court did not err when it denied services without making any explicit on-the-record findings. Appellant conceded to the physical harm allegations, and the evidence was undisputed. A finding can be inferred and is supported by substantial evidence.
Case Summaries