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Name: In re Tyler R.
Case #: B261136
Court: CA Court of Appeal
District 2 DCA
Division: 7
Opinion Date: 11/02/2015
Subsequent History: Review granted 1/27/2016: S231144; Review dismissed as moot 6/22/2016

Mother’s complete lack of interest in parenting the minor combined with her severe physical limitations amounted to substantial evidence to support jurisdiction and removal orders. Mother appealed the jurisdictional and dispositional findings declaring the minor a dependent and removing him from her custody. She contended that the juvenile court’s findings and orders were not supported by substantial evidence. The appellate court rejected her arguments. The evidence showed that mother’s severe physical limitations limited her physical ability to care for the minor. She could not speak, had very little control over her limbs, and relied on others to meet all of her daily living activities. Further, mother showed a lack of interest in the minor, and relied on relatives to financially support him despite her receipt of monthly disability income. Mother neither made any parenting-related decisions nor directed others who provided the minor’s care. The fact that the minor had been well cared for by family members, in spite of mother’s inability to care for him, did not preclude dependency jurisdiction. In addition, mother expressed a desire to reunite with the minor’s father, who had a history of significant violence against her. There was also substantial evidence that mother had been provided with reasonable services to prevent removal, but that she did not follow through.