Unreported / Non-Citable
Background
In July 2025, the Riverside County Department of Public Social Services took Jennifer R.'s seven minor children into protective custody after a domestic violence incident involving the father of her two youngest children and filed Welfare and Institutions Code section 300 dependency petitions. Prior investigations showed the mother's use of amphetamine or cocaine while pregnant with her youngest child, domestic violence in the children's presence, no evidence of school enrollment, unmet service needs, and a historic pattern of evading child welfare investigations by leaving the county or state.
At the July 30, 2025 detention hearing, the juvenile court detained the children and ordered the Department to provide drug testing, parenting education, substance abuse treatment, counseling, and other services, with supervised visits for the mother at least once a week. The court strongly encouraged her participation and warned that failure to participate regularly in reunification services could lead to termination at the six-month review and possible termination of parental rights. At the November 10, 2025 jurisdiction and disposition hearing, the court sustained a fourth amended section 300 petition, adjudged the children dependents, removed them from parental custody, and ordered family reunification services for the mother while denying services to fathers Raul G. and Victor R.
By the six-month review, the mother had not undertaken to participate in the referred services — domestic violence classes, parenting education, and individual counseling — and declined drug testing, substance use disorder screening, and treatment. Other than a September 2025 psychological evaluation, she did not participate in services before the November 2025 hearing; afterward she enrolled in individual counseling and contacted providers but failed to keep appointments or respond to outreach. In May 2026 her counsel provided a parenting-program certificate the provider confirmed had a falsified signature, plus a certificate for a 16-hour online domestic violence course the Department deemed inadequate because it lacked a live instructor, individual meetings, group discussions, and a personalized prevention plan. At the contested July 15, 2026 hearing, the juvenile court found by clear and convincing evidence that the Department offered reasonable services, the mother was unwilling and failed to participate regularly and make substantive progress, and there was no substantial probability the children would be returned with another six months; it terminated reunification services and set a section 366.26 permanent plan hearing.
The Court’s Holding
The Court of Appeal denied the petition. It noted at the outset that the mother's complaint was perplexing because she claimed the juvenile court erred in denying her reunification services under section 361.5, subdivisions (b)(10) and (b)(11), when the court in fact ordered services for her; the court read her claim as challenging whether the services offered and provided were reasonable.
The court found her claims lacked merit. Other than the September 2025 psychological evaluation, she did not participate in services before the November 2025 hearing, and the Department was not required to make new referrals because the reunification plan continued the same services it had offered since August 2025. The record refuted her assertions that the Department failed to communicate: between January and April 2026 the Department contacted or attempted to contact her 26 times in person, by telephone, or by text, yet she failed to keep appointments or respond to providers.
The court also rejected her claim that she deserved an additional six months because she demonstrated case compliance. The record showed only two certificates — the falsified parenting certificate and the last-minute 16-hour online domestic violence course that did not satisfy her service plan — with no evidence of a second domestic violence course or any anger management program. The record established that the Department offered and provided reasonable services but the mother chose not to participate in them.
Key Takeaways
- A parent who claims she was denied family reunification services cannot prevail when the juvenile court actually ordered services and the record shows she failed to participate in them.
- A child welfare agency is not required to make new service referrals after the jurisdiction and disposition hearing if the reunification plan continues the same services already offered.
- A parenting certificate with a falsified signature, submitted by counsel, undermines a parent's claim of compliance with a family reunification plan.
- A short online domestic violence course without a live instructor, individual meetings, group discussions, or a personalized prevention plan may be deemed inadequate to satisfy the plan's domestic violence component.
- A finding, supported by clear and convincing evidence, that a parent failed to participate regularly and make substantive progress justifies terminating reunification services and setting a section 366.26 permanent plan hearing.
Why It Matters
This unpublished decision reinforces that parents in juvenile dependency proceedings must actively engage in court-ordered reunification services; merely enrolling in programs or producing last-minute or falsified certificates does not constitute substantive progress. It also confirms that agencies satisfy their reasonable-services obligation by making referrals and maintaining contact with parents, and that the six-month review is a critical juncture — particularly where the youngest child was under three when removed — after which nonparticipation can lead to termination of services and a permanent plan hearing that may end in adoption.