In re Daniel T.
Angelica C. (Mother) appeals from the juvenile courtâ€™s May 29, 2013 jurisdictional and dispositional orders, contending that substantial evidence does not support the courtâ€™s order declaring minor Daniel T. II a dependent of the court pursuant to paragraph b-3 of the petition alleged under Welfare and Institutions Code section 300, subdivision (b) (failure to protect) based on Motherâ€™s alleged drug use. She also contends that the court abused its discretion in making a dispositional order requiring her to submit to random drug testing. Mother does not appeal from the orders sustaining other allegations under section 300, subdivisions (a) (serious physical harm) and (b). Daniel T. (Father) is not a party to this appeal.
We conclude that because Motherâ€™s drug use was remote in time and had no causal nexus to substantial risk of serious harm to the minor, the jurisdictional order based on Motherâ€™s alleged drug use is not supported by substantial evidence. We also conclude that the court abused its discretion in requiring Mother to submit to random drug testing. We reverse only as to the challenged jurisdictional and dispositional orders.