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Name: In re T.W. et al.
Case #: A148171
Court: CA Court of Appeal
District 1 DCA
Division: 5
Opinion Date: 02/02/2017

Finding of reasonable services was reversed where father was provided only one telephone visit despite requests for more visitation. Father was incarcerated out of state. The Department recommended services for him, but did not make specific referrals. Father received only one telephone visit with the minors, despite his request for more. At the six-month review hearing, father contended that reasonable services had not been provided, citing a delay in preparing his case plan and the failure to address drug treatment or provide regular phone visitation. The Department acknowledged the failures but argued that services had been reasonable given that father was out of state and that a new social worker was assigned in the middle of the case. The juvenile court found that reasonable services had been provided. The appellate court reversed that finding. The initial case plan failed to identify any service providers and put the burden on father. The amended program identified one program, but contained no further instructions. Only after three months was father provided with specific contact numbers. The revised case plan provided no drug testing, and no housing services. Further, the provision of a single visit during a six month review period was not reasonable. Father’s out of state location did not excuse the Department’s failure to identify and provide services, or its failure to set up more than one telephone visit with the minors. The likelihood of reunification with father may be low, but he was nonetheless entitled to reasonable services.