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Name: F.K. v. Superior Court (2024) 100 Cal.App.5th 928
Case #: B333788
Court: CA Court of Appeal
District 2 DCA
Division: 6
Opinion Date: 03/18/2024

The juvenile court has discretion at the six-month review hearing to continue reunification services even if it finds there is not a substantial probability the child will be returned to the parent. Minor was removed from Mother due to alcohol abuse and domestic violence. Following removal, Mother engaged in alcohol treatment, therapy, and domestic violence treatment, although Mother continued to experience denial and relapse. At the six-month review hearing the juvenile court said that it could not grant more services unless Mother showed she had substantially complied with her case plan. The juvenile court terminated reunification services and set a…

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Name: L.C. v. Superior Court (2024) 98 Cal.App.5th 1021
Case #: B331041
Court: CA Court of Appeal
District 2 DCA
Division: 7
Opinion Date: 01/16/2024

Substantial evidence did not support the juvenile court’s finding that it would be detrimental to return Minor to Mother based on Mother’s decision to remain in Mexico throughout the dependency case. The minor was removed from Mother when Mother was arrested for transporting Fentanyl. Father was never located. Mother returned to Mexico on the advice of her attorney and remained there throughout the case. Mother completed a drug program in Mexico and maintained a relationship with Minor through frequent video calls. Maternal grandparents, who also lived in Mexico, were approved by an international ICPC. The juvenile court was disapproving that…

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Name: In re Damian L.
Case #: F083805
Court: CA Court of Appeal
District 5 DCA
Opinion Date: 04/11/2023

Juvenile court erred in ordering additional services to Mother at the section 387 disposition hearing because she had already received over 24 months of services. The minors were taken into custody and Family Maintenance (FM) services were ordered for Mother. Following a positive drug test by Mother, the minors were removed and placed with maternal grandmother. Family Reunification (FR) services were ordered for Mother. A few months later, a section 387 petition was filed to remove the minors from maternal grandmother. At the combined section 387 disposition/24-month review hearing, the juvenile court found that the reunification timeline does not run…

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Name: Michael G. v. Superior Court (2023) 14 Cal.5th 609
Case #: S271809
Court: CA Supreme Court
Opinion Date: 04/06/2023

A parent who has not received reasonable services during the 12-18 month review period may seek an extension of services beyond 18 months, but such extensions are not automatic. The minor was removed from Father and a dependency petition was sustained. The juvenile court found that reasonable services had been provided at the 6 and 12-month review hearings and extended services to an 18-month review hearing. At the 18-month review hearing, the juvenile court found that reasonable services had not been provided, but declined to order additional reunification services, and set the matter for a permanency hearing. Father filed a…

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Name: Sarah K. v. Superior Court
Case #: A165607
Court: CA Court of Appeal
District 1 DCA
Division: 2
Opinion Date: 01/17/2023
Subsequent History: DEPUBLISHED on 4/12/2023 (S278324)

Substantial evidence supported the setting of a section 366.26 hearing despite Mother’s progress in reunification services where she had a history of drug use and relapse, a prior dependency case, and the minor had grown attached to her foster family. Although the present case was initiated due to domestic violence, Mother had a history of substance abuse and prior dependency cases. Family maintenance services were unsuccessful. Following the minor’s removal pursuant to a section 387 petition, Mother engaged in substance abuse treatment. Between the six and twelve-month review hearings, Mother struggled with her sobriety. At the twelve-month review hearing, the…

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Name: In re D.N.
Case #: B302910
Court: CA Court of Appeal
District 2 DCA
Division: 1
Opinion Date: 10/27/2020

Where father's failure to reunify with the minor was due solely to poverty, the juvenile court abused its discretion by denying father additional time to secure stable housing. Minor was detained from his mother in 2013 due to mother's substance abuse. When father was located, he sought custody, but did not have stable housing. Father received reunification services, but despite "sincere efforts" he continued to have challenges with housing and transportation. Father had a good relationship with the minor, who wanted to live with him. Minor, who was a teenager, was failing in group and foster placements. The Department recommended…

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Name: Georgeanne G. v. Superior Court
Case #: B301629
Court: CA Court of Appeal
District 2 DCA
Division: 7
Opinion Date: 08/18/2020

Order terminating services and setting a 366.26 hearing was reversed where there was insufficient evidence that return of the minor to mother would cause a substantial risk of harm to his safety or well-being. Mother sought extraordinary relief from an order terminating her reunification services and setting a hearing pursuant to Welfare and Institutions Code section 366.26. Mother contended that the juvenile court erred when it considered her purported lack of insight into the problems leading to the minor's removal. She argued that her purported lack of insight was not a proper ground for terminating services and…

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Name: M.G. et al. v. Superior Court
Case #: G058611
Court: CA Court of Appeal
District 4 DCA
Division: 3
Opinion Date: 03/16/2020

Juvenile court order terminating reunification services and setting a 366.26 hearing was reversed where there was no evidence to support a conclusion that there was a risk to the minors if returned to their parents. Minors were removed from parents because father was incarcerated and mother was using drugs, was homeless, and had exposed the minors to domestic violence. The minors were removed, and reunification services were ordered. By the 12-month review hearing, both parents had made moderate progress, and the court continued reunification services and expanded visitation. The Department recommended termination of services at the…

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Name: In re M.F.
Case #: D074260
Court: CA Court of Appeal
District 4 DCA
Division: 1
Opinion Date: 01/11/2019

Juvenile court did not err by extending services past the 18-month review hearing date for a minor under three where the Agency did not provide reasonable services. At a 12-month review hearing, the juvenile court found that reasonable services had not been provided to father, and ordered the Agency to extend the reunification period for an additional six-month period, setting the 18-month review hearing more than 23 months after the two-year-old minor first entered foster care. The minor appealed, challenging the reasonable services finding, and contending that the juvenile court lacked the authority to order continued services beyond the…

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Name: J.H. v. Superior Court
Case #: B284802
Court: CA Court of Appeal
District 2 DCA
Division: 6
Opinion Date: 02/15/2018

"Sanchez" limits on expert opinion testimony do not render social workers' reports inadmissible in dependency cases. At a status review hearing, the court permitted over objection the testimony of the supervisor of the writer of the social report. She testified there was not a substantial probability that the minors would be returned to father within the next six months. The court found that People v. Sanchez (2016) 63 Cal.4th 665 did not apply, terminated reunification services, and set the matter for a 366.26 hearing. Father petitioned for writ review, contending the court erred when it…

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