Filed 9/16/26 In re A.I. CA2/4
NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS
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IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA
SECOND APPELLATE DISTRICT
DIVISION FOUR
In re A.I. et al., Persons Coming B348617
Under the Juvenile Court Law.
LOS ANGELES COUNTY Los Angeles County
DEPARTMENT OF Super. Ct. No.
CHILDREN AND FAMILY 24CCJP01818A–B
SERVICES,
Plaintiff and Appellant, and
RAMON I.,
Defendant and Appellant,
v.
JACQUELINE R.,
Defendant and Respondent.
APPEALS from orders of the Superior Court of Los Angeles
County, Georgia Huerta, Judge. Affirmed and remanded with
directions.
Dawyn R. Harrison, County Counsel, Kim Nemoy,
Assistant County Counsel, and Kimberly Roura, Principal
Deputy County Counsel, for Plaintiff and Appellant.
Emery El Habiby, under appointment by the Court of
Appeal, for Defendant and Appellant.
No appearance for Respondent.
_________________________________________
When terminating jurisdiction over a dependent child, the
juvenile court may issue a custody and visitation order commonly
referred to as an exit order. (Welf. & Inst. Code, § 362.41;
Cal. Rules of Court, rule 5.700; In re Anna T. (2020) 55
Cal.App.5th 870, 871 (Anna T.).) Exit orders are effective after
juvenile dependency proceedings have ended only if issued on a
signed mandatory Judicial Council of California form JV-200.
(Anna T., at pp. 878–880.) The juvenile court’s confidential
minute orders, on the other hand, have no force after dependency
proceedings end. (Id. at p. 879.)
R.I. (father) and the Los Angeles County Department of
Child and Family Services (department) appeal from the juvenile
court’s order terminating jurisdiction because the court issued
custody and visitation orders without using form JV-200.
Though the court did not use the proper procedure, it committed
no reversible error. We therefore affirm the order and remand to
direct the court to issue its order on form JV-200.
BACKGROUND
Dependency proceedings for father’s two minor children
began in June 2024 after father was arrested for driving under
the influence of alcohol with mother and their infant in the
vehicle. The department filed a dependency petition alleging the
1 All undesignated statutory references are to the Welfare and
Institutions Code.
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parents’ two children were subject to juvenile court jurisdiction
under section 300, subdivisions (b)(1) and (j). The court detained
the children from both parents. Initially, the court found father
was the alleged father of both minors. After DNA testing, the
court found him to be the biological father.
In January 2025, the court sustained the dependency
petition on multiple counts and declared both minors were
dependents of the court. At a review hearing in August 2025, the
court terminated jurisdiction. In a minute order dated August
14, 2025, the court found continued supervision was unnecessary,
gave mother sole legal and physical custody, and ordered
monitored visits for father. The court also terminated
jurisdiction pending receipt of a juvenile custody order.
The court then reconsidered that ruling. Mother argued
the court should not issue a juvenile custody order because father
was the biological (not presumed) father, was not involved in the
children’s lives, had not completed his case plan, and was not
visiting the children. The department responded that mother’s
concerns about father were irrelevant. It asserted that rather
than unduly elevating father’s status, a juvenile custody order
would protect mother. Father agreed. He argued that, as a
biological father, he is entitled to visitation, and the court should
issue a juvenile custody order on form JV-200.
After the court declined to issue a signed juvenile custody
order on form JV-200, the parents each requested that the
minute order terminating jurisdiction specify the court’s orders
on custody and visitation. The department interjected that
dependency minute orders are confidential to family law courts.
Though the court chose not to issue a juvenile custody order on
Judicial Council form JV-200, father requested that the court
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include in the minute order the reasons for the court’s ruling on
visitation, which would have been included on form JV-206. The
court agreed to state its reasons in the minute order dated
August 20, 2025.
Father and the department timely appealed the August 14,
15, and 20, 2025 orders. 2
DISCUSSION
Juvenile custody orders made via minute order become
ineffective once dependency jurisdiction ends. Under section
362.4 and California Rules of Court, rule 5.700, the juvenile court
must make any juvenile custody orders on mandatory form JV-
200. (Anna T., supra, 55 Cal.App.5th at pp. 878–880.) By doing
so, the juvenile court gives a family court guidance on when to
modify custody orders “ ‘without disclosing juvenile case
information that should remain confidential, because juvenile
court child custody orders, including attachments, are not
themselves confidential.’ ” (Id. at p. 879.) If the juvenile court
does not use this procedure, its orders “regarding custody and
visitation are effective only while that court exercises its
jurisdiction over the child” and are therefore “no longer valid”
when the court terminates dependency jurisdiction. (Ibid.)
Here, the court’s minute orders terminated jurisdiction and
simultaneously purported to give mother sole legal and physical
custody of each minor and authorize monitored visits for father.
But because the juvenile court issued confidential minute orders
instead of using mandatory form JV-200, the orders immediately
2 The court’s August 15, 2025 order merely memorializes that a
hearing did not take place on that date. For each child, the court
issued an identical order on August 14, 15, and 20.
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became ineffective. (Anna T., supra, 55 Cal.App.5th at pp. 878–
880.)
Appellants have not shown, however, that the juvenile
court erred in its substantive adjudication of custody and
visitation. Indeed, appellants do not contend the court made any
such error. We presume the challenged orders are correct. (In re
M.V. (2025) 109 Cal.App.5th 486, 518.) Appellants have not
shown otherwise. We therefore do not reverse the juvenile court’s
orders. Instead, we remand to the juvenile court and direct it to
issue a new order on mandatory form JV-200 (and its associated
attachments).
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DISPOSITION
The juvenile court’s August 14, 15, and 20, 2025 orders are
affirmed. The matter is remanded to the juvenile court with
directions to issue its custody and visitation orders on form JV-
200 with attachment JV-206 and all other applicable
attachments on Judicial Council of California forms.
NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS
TAMZARIAN, J.
We concur:
ZUKIN, P. J.
DAUM, J.
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