Dispositional Hearings

Name: In re L.G.
Case #: A173218
Court: CA Court of Appeal
District 1 DCA
Division: 4
Opinion Date: 03/06/2026

Insufficient evidence supported the removal of Minor at dispositional hearing where Agency failed to present evidence that removal was necessary or that the Agency had made reasonable efforts to prevent the need for removal. Mother had a history of mental health issues. When L.G. was about six months old, Mother’s mental health deteriorated. She agreed to a safety plan where Maternal Grandmother (MGMA) provided primary care for L.G. When Mother attempted to retrieve L.G. from MGMA, the Agency filed a section 300 petition and detained her. Mother sought mental health treatment and made improvements prior to the jurisdiction hearing. At…

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Name: In re S.R.
Case #: S285759
Court: CA Supreme Court
Opinion Date: 12/01/2025

A parent’s appeal was not moot because the harm she would suffer from inclusion on the California’s Child Abuse Central Index (CACI) could be redressed if she prevailed on challenging the child abuse allegation on appeal.  After a physical confrontation between Mother and two of her daughters, the juvenile court removed the two youngest daughters from the home. Mother appealed. The Court of Appeal dismissed Mother’s appeal as moot because the children were eventually returned to her care. The Supreme Court held that Mother’s appeal was not moot because (1) she showed ongoing harm due to…

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Name: In re Miguel J.
Case #: B339932
Court: CA Court of Appeal
District 2 DCA
Division: 8
Opinion Date: 09/22/2025

There was sufficient evidence to support section 300, subdivision (a) allegations where Father struck Mother while she was holding Minor. Minor was detained from Father and released to Mother after police were called to a domestic violence incident. Father struck Mother while she was holding four-month old Minor and accidentally struck Minor. Mother stayed at a shelter for a week with Minor but then returned to the family home. The juvenile court sustained domestic violence counts under Section 300, subdivisions (a) and (b). Family Maintenance services were ordered for Mother and enhancement services for Father. Father appealed and the reviewing…

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Name: In re A.M.
Case #: B343879
Court: CA Court of Appeal
District 2 DCA
Division: 8
Opinion Date: 09/18/2025

Juvenile court erred in removing Minor from incarcerated Father who had made a suitable plan for Minor’s care. Father had been granted sole physical and joint legal custody of Minor. When Father became incarcerated, he arranged for his sister to care for Minor. When Mother learned of Father’s incarceration, she refused to return Minor to paternal aunt and then neglected Minor, leading to the present dependency case. The juvenile court sustained jurisdictional allegations against Father based on his criminal history and removed Minor from both parents. Minor appealed and the reviewing court reversed. Section 361(d) is applicable here because Minor…

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Name: In re Miguel J.
Case #: B339932
Court: CA Court of Appeal
District 2 DCA
Division: 8
Opinion Date: 09/22/2025

Substantial evidence supported jurisdiction under WIC 300(a) because Father and Mother engaged in multiple acts of domestic violence that exposed child to substantial risk of nonaccidental harm. Additionally, modification of the language in the counts to reflect that Father hit child accidentally while hitting Mother was not required because the current language accurately reflected the court’s findings. Substantial evidence supported removing the child from Father’s custody because Father and Mother intended to maintain relationship and there was strong likelihood violence between them would continue.

The full opinion is available on the court’s website…

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Name: In re Jayden A.
Case #: E084114
Court: CA Court of Appeal
District 4 DCA
Division: 2
Opinion Date: 06/13/2025

There was insufficient evidence to support the jurisdiction findings as to Father. Minor was detained following a domestic violence incident between Mother and Mother’s boyfriend. Father had ADHD which he was treating through individual counseling. Paternal grandmother reported that Father could become overwhelmed by parenting and would leave Jayden in her care while he took the time and space he needed. Father tested positive for marijuana on three occasions and reported he had been a victim of Mother’s domestic violence previously, when they were in a relationship. At the combined jurisdiction and disposition hearing, the juvenile court found true jurisdictional…

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Name: In re B.L.
Case #: E085039
Court: CA Court of Appeal
District 4 DCA
Division: 2
Opinion Date: 05/14/2025

A single DUI accident, which resulted in significant injury to Minor, is sufficient for jurisdiction. Minor suffered a significant brain bleed as a result of a DUI car accident where Mother crashed into a utility pole at 65-70 mph. Mother then attempted to stop a Good Samaritan from contacting emergency services because she did not want her child taken away. Minor was detained from Mother and placed with Father, who had ended his relationship with Mother as a result of the accident. At the combined jurisdiction and disposition hearing, the juvenile court found jurisdiction pursuant to subdivisions (b) and (e),…

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Name: In re A.T.
Case #: D085053
Court: CA Court of Appeal
District 4 DCA
Division: 1
Opinion Date: 04/14/2025

Father is a noncustodial parent pursuant to Welfare and Institutions Code section 361.2, subdivision (a) where he learned he was the child’s father after the child was detained from Mother. Minor was detained when Mother and Minor tested positive for illegal substances at the time of birth. Mother and Father were in an on-and-off relationship and have two older children together. Mother was not sure who had fathered Minor. Father was not present at the birth nor was he listed on the birth certificate. At the combined jurisdiction and disposition hearing, the juvenile court found Minor to be a dependent…

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Name: In re Baby Girl R.
Case #: H051362
Court: CA Court of Appeal
District 6 DCA
Opinion Date: 11/08/2024

The juvenile court is not required to bypass services when the parent’s whereabouts remain unknown. Mother left Minor at the hospital after giving birth and the Agency was unable to locate Mother. At the disposition hearing, the juvenile court ordered services for Mother over Minor’s objection. The Minor appealed and the reviewing court affirmed. Despite the termination of Mother’s services at the six-month review hearing, the court exercised its discretion to consider the matter despite mootness because it was an important question of statutory interpretation. While some bypass provisions are mandatory, bypass under section 361.5, subdivision (b)(1) [whereabouts of parent…

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Name: In re H.B.
Case #: A169493
Court: CA Court of Appeal
District 1 DCA
Division: 2
Opinion Date: 10/08/2024

Father’s removal from family home and order of supervised visitation falls under section 361, subdivision (c) rather than section 362, subdivision (c). The juvenile court found jurisdiction over the minors based mainly on Father’s substance abuse issues. At the disposition hearing, the juvenile court found section 362, subdivision (c) was applicable because the minors remained in the home with a custodial parent. It ordered placement with Mother and supportive services to Father, who had moved out of the home. Father appealed and the reviewing court reversed. Section 361, subdivision (c) applies when the juvenile court is considering removing a…

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