The minor was first removed from her mother in 1999 and was returned on Family Maintenance 12 months later following mother’s successful completion of a reunification program, which included substance abuse rehabilitation. Six months later, dependency jurisdiction was terminated. In February of 2002, a new dependency action began when the grandparents reported that mother had been gone for a month. The grandparents believed that mother was abusing drugs again. The petition was sustained, and at a disposition hearing, mother was denied reunification services pursuant to Welfare and Institutions Code section 361.5, subdivision (a). Here, the appellate court reversed that order. A parent is not precluded from receiving reunification services solely because she received 18 months of services in a previous dependency proceeding where she successfully reunified with her child. None of the 15 exceptions to section 361.5 authorizes denial of reunification under these circumstances.
Case Summaries