Dependency (300)

Name: In re N.J.
Case #: E086829
Court: CA Court of Appeal
District 4 DCA
Division: 2
Opinion Date: 06/25/2026

A court makes an implicit presumed father finding when it treats a father as a presumed father. Minor was removed from Mother due to substance abuse. Father was named on Minor’s birth certificate and present at her birth but had not lived in the family home for over a year. Father appealed the jurisdictional and dispositional findings. On remand for other issues, the reviewing court ordered that the juvenile court make explicit its presumed father finding. The doctrine of implied findings presumes that the juvenile court made all implied findings to support its judgment. Here, the jurisdiction and disposition orders…

View Full Summary
Name: In re A.T.
Case #: E086411
Court: CA Court of Appeal
District 4 DCA
Division: 2
Opinion Date: 06/05/2026

Welfare and Institutions Code section 300, subdivision (e) is applicable only where a child is under the age of five at the time of the jurisdiction hearing. Minor was detained from Guardian based on physical abuse and mistreatment that occurred when he was four years old. A petition was filed which included an allegation under section 300(e) which pertains to abuse of children under five years old. By the time of the jurisdiction hearing, Minor had turned five. The juvenile court found true the section 300, subdivision (e) allegations, among other allegations. Guardian appealed and the reviewing court reversed. For…

View Full Summary
Name: In re N.J.
Case #: E086829
Court: CA Court of Appeal
District 4 DCA
Division: 2
Opinion Date: 06/25/2026

The juvenile court erred when it treated appellant as a presumed father without making an express finding that he was the presumed father. There was substantial evidence supporting an implied finding that appellant was the presumed father, and the juvenile court was therefore directed to make an explicit finding of presumed father status.

The full opinion is available on the court’s website here:

View Full Summary
Name: In re K.L.
Case #: B348185
Court: CA Court of Appeal
District 2 DCA
Division: 8
Opinion Date: 05/18/2026

Indian Child Welfare Act (ICWA) inquiry was sufficient despite failure to interview maternal grandmother. Following the detention of the minor K.L, the Agency inquired about Indian ancestry with the parents and all available family members except the maternal grandmother. The Agency did not have contact information for the maternal grandmother, but she was involved in the lives of K.L.’s half siblings and other relatives. Father challenged the ICWA inquiry in his appeal from the termination of his parental rights and the reviewing court affirmed. The Agency has an obligation to contact extended family members who are reasonably available, but is…

View Full Summary
Name: In re O.M.
Case #: A173461
Court: CA Court of Appeal
District 1 DCA
Division: 2
Opinion Date: 05/07/2026

Juvenile court erred in dismissing jurisdiction where the evidence compelled a finding, as a matter of law, that Minors were at risk for malnutrition. A petition was filed for O.M. and his younger sibling after O.M. was hospitalized for a broken femur. At the hospital, O.M was also treated for malnutrition as his weight was less than 1% on the growth charts. Mother testified at the jurisdiction hearing that the family followed a vegan diet but she understood that she needed to feed O.M more calories. Mother also expressed that O.M. was a picky eater and that she still didn’t…

View Full Summary
Name: In re Z.G.
Case #: S289430; S289441; E083710; E084563
Court: CA Supreme Court
Opinion Date: 04/27/2026

Juvenile court may not terminate parental rights merely by finding a likelihood of adoption when a parent did not receive reunification services and was not bypassed for such services. Z.G. was removed due to parental substance abuse and domestic violence. Mother improved her situation and Z.G. was returned to her care on a family maintenance program. A.G. was born shortly thereafter and both Minors were removed from Father but remained in Mother's care. After 18 months, the Agency filed a section 387 supplemental petition and Minors were removed from Mother. The juvenile court terminated services and set a section 366.26…

View Full Summary
Name: Steven N. v. Priscilla C.
Case #: D085731
Court: CA Court of Appeal
District 4 DCA
Division: 1
Opinion Date: 03/26/2026

The court erred in failing to set aside a voluntary declaration of parentage (VDOP) where biological mother was married to another man at the time of the birth of the child. Priscilla and Steven signed a VDOP that they were the parents of Stella in the days after her birth. When Steven filed a petition for custody two years later, Priscilla moved to set aside the VDOP because she was married to Gianni at the time the VDOP was signed. The court denied the motion, finding that the marriage was not valid because Priscilla and Gianna were not living together…

View Full Summary
Name: In re Marriage of Hoch
Case #: G063467
Court: CA Court of Appeal
District 4 DCA
Division: 3
Opinion Date: 02/17/2026

The court erred in ordering mutual Domestic Violence Restraining Orders (DVROs) where the evidence did not support that Marcie was a primary aggressor. Michael and Marcie requested mutual DVROs. Michael had repeatedly used a tracking device to monitor Marcie’s movements, appeared uninvited at her home and refused to leave, and accessed her digital devices without permission. Marcie had retrieved items from their previously shared home without permission, looked into Michael’s new car while it was parked at the gym, and attended a party at the same complex where Michael was occupying their beach home. The court issued mutual restraining orders.…

View Full Summary
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…

View Full Summary
Name: J.S v. D.A.
Case #: D086356
Court: CA Court of Appeal,CA Superior Court
District 4 DCA
Division: 1
Opinion Date: 02/25/2026

The court abused its discretion when it held a Domestic Violence Restraining Order (DVRO) evidentiary hearing in incarcerated D.A.’s absence without considering options to provide him access to the court. J.S. requested a DVRO protecting her from D.A., who was in prison. The court set an evidentiary hearing and D.A. said he would like to participate telephonically. The court held the hearing in D.A.’s absence without conducting a custody check or attempting to provide D.A. access to the hearing, and issued a five-year DVRO. D.A. appealed and the reviewing court reversed and remanded for a hearing. Indigent inmates who are…

View Full Summary