Filed 8/28/26 In re J.G. CA2/5
NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS
California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions
not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion
has not been certified for publication or ordered published for purposes of rule 8.1115.
IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA
SECOND APPELLATE DISTRICT
DIVISION FIVE
In re J.G., a Person Coming B349097
Under the Juvenile Court Law. (Los Angeles County
Super. Ct. No.
24CCJP02967A)
LOS ANGELES COUNTY
DEPARTMENT OF
CHILDREN AND FAMILY
SERVICES,
Plaintiff and Respondent,
v.
V.G.,
Defendant and Appellant.
APPEAL from an order of the Superior Court of Los
Angeles County, Safaan K. Ahmed, Judge. Affirmed.
Gina Zaragoza, under appointment by the Court of Appeal,
for Defendant and Appellant.
Dawyn R. Harrison, County Counsel, Jacklyn K. Louie,
Assistant County Counsel, Sarah Vesecky, Principal Deputy
County Counsel, for Plaintiff and Respondent.
_____________________
I. INTRODUCTION
V.G. (mother) appeals from the juvenile court’s
September 16, 2025, order at the Welfare and Institutions Code1
section 366.21, subdivision (f), 12-month review hearing
regarding J.G. (the child, born 2009). She challenges the finding
that the Department of Children and Family Services (the
Department) provided her with reasonable reunification services
as not supported by substantial evidence. We affirm.
II. BACKGROUND
This is mother’s second challenge to the juvenile court’s
finding that the Department has provided her with reasonable
services. (See In re J.G. (Mar. 17, 2026, B346038) (J.G. I).) As in
her previous appeal, mother’s challenge is based on the
Department’s failure to provide conjoint therapy with the child.
1 Further undesignated statutory references are to the
Welfare and Institutions Code.
2
In our prior unpublished opinion, we affirmed the juvenile
court’s order at the six-month status review hearing finding the
Department had provided mother with reasonable services and
continuing family reunification services. The following factual
and procedural summary is taken from the opinion in J.G. I,
supra, B346038:
“A. Jurisdiction
“On September 19, 2024, the Department filed a section
300 petition that alleged, as later sustained by the juvenile court,
the following counts:
“a-1 and b-1: ‘[Mother] has a history of engaging in violent
and assaultive behavior in the presence of the child. On
01/25/2023, ... mother repeatedly struck adult sibling, [sister] on
[her] back and shoulder with a pair of headphones. ... [M]other
used both hands to pull [sister’s] hair. The child intervened and
separated ... mother and [sister]. On prior occasions, ... mother
threw clothing and items at maternal grandmother ... . Such
violent conduct on the part of ... mother endangers the child’s
physical health and safety, creates a detrimental home
environment, and places the child at risk of serious physical
harm, damage, and danger.’
“b-2: ‘[Mother] has mental and emotional problems,
including paranoia, which renders ... mother unable to provide
regular care of the child. Such mental and emotional problems
on the part of ... mother endangers the child’s physical health and
safety, creates a detrimental home environment, and places the
child at risk of serious physical harm, damage, and danger.’[(Fn.
omitted.)]
3
“On October 15, 2024, the Department filed its
jurisdiction/disposition report. The child reported that in
September 2024, mother struck him on the chest, and that
‘“[mother] says she is okay, but clearly she is not. We tried to get
her help, but she said no. If I was ever going to live with my
mom again, she would need to get help. Otherwise, it will be a
living hell.”’ Sister reported that she and the child are scared
because they ‘“don't know what [mother]’s going to do or what
she’s capable of.”’
“On September 6, 2024, the social worker spoke with an
employee at the child’s school who explained that mother had
come to the school numerous times to demand that the school
take away the child’s phone because the child had done
something to mother’s phone.
“The dependency investigator reported that on October 2,
2024, mother waited in the parking lot instead of coming into the
building for her scheduled interview or otherwise informing the
investigator she had arrived. She fidgeted with her arms and
hands, walked at an angle, and frequently went off topic. Mother
told the investigator that someone was tampering with her
phone; she suspected it was sister and the child. She denied
paranoia or any other mental health problems except anxiety.
She refused treatment and stated that she was ‘“not going to do
the mental health appointments.”’
“At the October 29, 2024, adjudication and disposition
hearing, mother denied having any mental health issues other
than anxiety around small spaces. She provided proof that she
had attended a physical examination on October 21, 2024, and
claimed to have scheduled an appointment with a psychiatrist for
November 1, 2024, to assuage concerns about her mental health.
4
“The juvenile court sustained the section 300 petition,
declared the child a dependent of the court, removed him from
mother’s custody, and ordered him suitably placed with sister. It
granted a temporary restraining order protecting sister from
mother.[2]
“The juvenile court ordered the Department to provide
mother with reunification services, housing and transportation
assistance, and to refer mother for a neurological assessment.
The court ordered that mother be provided a minimum of two
hours a week of monitored visitation with the child. Finally, the
court ordered, as part of the case plan, that mother participate in
‘[c]onjoint counseling with [the child] when recommended by [the
child’s] therapist, individual counseling to address the case
issues, including anger management and mental health. Mother
is to submit to a psychological assessment, psychiatric
evaluation, and take all prescribed psychotropic medications.’
The court ordered mother to follow the standing orders of the
case plan, including that she ‘sign any form necessary to release
information to [the Department] with regard to all court-ordered
counseling (HIPAA).’
“The juvenile court ordered that the child participate in
age-appropriate counseling and conjoint therapy with mother if
the child’s therapist recommended it.
2 On November 18, 2024, the juvenile court issued a three-
year restraining order protecting sister from mother. On
October 2, 2024, another superior court issued a one-year
restraining order protecting maternal grandmother from mother.
5
“B. Reunification Period ([Six Month] Status Review Report)
“On April 21, 2025, the Department filed a status review
report. The Department reported that the child was ‘thriving’ in
the care of sister. He had gained weight, improved academically,
formed friendships at school, and become a confident and happy
teenager.
“The social worker supervised family visits between mother
and the child and reported that although mother was caring and
loving during the visits, she spent most of her time ‘venting’ to
the child about her difficult economic situation, which caused the
child to worry. On one occasion, the child asked the social worker
to end the visit early ‘because of how uncomfortable and sick to
his stomach he felt.’ The child canceled most of his visits because
of anxiety. The child wrote to the social worker in a text
message: ‘“I am so sorry but I can’t see my mom t[o]m[o]r[row.] I
just can’t it’s so hard for me to see her i[n] that position and just
bring[s] me a lot of anxiety I am so sorry.”’
“In compliance with the juvenile court’s order, on
November 12, 2024, the child began to receive regular age-
appropriate therapy. The therapist reported that the child
avoided discussing his trauma and required ‘“more time, gradual
steps, and the development of effective coping skills to feel
prepared to discuss his experiences.”’ The therapist also reported
that the child had begun to express feelings of ‘“severe anxiety”
before and during family time.’ The child’s high anxiety levels
negatively affected his emotional well-being, daily functioning,
and relationships at school and home. The therapist
recommended that the child’s ‘“emotional well-being be
prioritized by allowing him to decide when he feels emotionall[y]
6
ready to visit his mother.”’ The therapist opined that the child
was not ready to have conjoint therapy sessions with mother.
“The child expressed that he had not felt safe or loved when
he lived with mother. He said he had not yet healed from the
traumatic experiences he endured in mother’s care and wanted
sister to adopt him.
“Mother continued to exhibit signs of paranoia by, among
other things, accusing sister of deleting items from mother’s
phone when the phone was never in sister’s possession. She did
not provide any confirmation that she attended a neurological or
psychiatric evaluation.[(Fn. omitted.)] She self-reported that she
attended nine individual therapy sessions between November 21,
2024, and April 16, 2025, but the Department could not verify
mother’s report because she refused to provide a HIPAA release
for the Department to obtain her medical records and review her
compliance with an assessment, diagnosis and treatment plan.
“The Department recommended that the juvenile court
continue reunification services for another six months to allow
mother more time to comply with the court orders and seek
treatment.
“C. [Six-Month] Status Review Hearing
“On April 29, 2025, the juvenile court conducted a section
366.21, subdivision (e) status review hearing. The court admitted
into evidence the Department’s reports and two documents that
mother submitted. Mother’s first document was an after visit
summary indicating mother had a video visit with a licensed
marriage and family therapist on April 16, 2025, and scheduled
another visit for April 23, 2025. The second document indicated
7
that mother saw the therapist again on April 23, 2025, and had
another video visit with him scheduled for that same day.
“The Department asked the juvenile court to again order
mother to sign release of information forms so the Department
could assess her progress.
“The child’s counsel requested that the child remain
suitably placed, that mother continue to receive reunification
services, and that the juvenile court modify its visitation order to
reduce visitation to twice a month based on the recommendation
of the child’s therapist.
“Mother’s counsel requested that the child be returned to
mother’s custody and argued that mother had complied with the
Department’s requests. Alternatively, counsel asked for a finding
of no reasonable services ‘due to the lack of visitation and lack of
conjoint counseling taking place between this mother and child.’
Counsel further requested that the court modify mother’s case
plan to state that conjoint counseling was to begin forthwith, and
to order the Department to ensure mother received her court-
ordered visits.
“Following argument by counsel, the juvenile court found,
by clear and convincing evidence, that the Department had
provided the family with reasonable services. The court found
that it would be detrimental to return the child to mother’s
custody at that time but ordered that mother continue to receive
reunification services. The court opined that conjoint counseling
was ‘probably the best way in which they[ would] be able to
reunify,’ but agreed with the child’s therapist’s view that the
child ‘needs some more time to be able to properly process what
has happened to him’ before he would be ready for conjoint
counseling; it thus denied mother’s request to modify the case
8
plan. The court ordered the current visitation schedule of two
hours per week would ‘remain in full force and effect’ and the
Department must ‘[e]nsure that the [child] is making full weekly
visits with mother’ and then set a three-month progress report
hearing to address visitation and counseling.” (J.G, I, supra,
B346038.)
D. Prior Appeal
In J.G., I, mother challenged the juvenile court’s finding at
the six-month review hearing that the Department had provided
her with reasonable services. She argued then, as she does now,
that the services were not reasonable because conjoint counseling
for mother and child had not yet commenced. We referenced that
“the disposition order included a case plan that included conjoint
counseling when recommended by the child’s therapist.” (J.G. I,
supra, B346038; italics added.) We explained that it was the
opinion of the child’s therapist that the child, who experienced
feelings of anxiety regarding visitation with mother, was not yet
ready to commence conjoint counseling. (Id.) The therapist’s
opinion “was supported by the child’s statements to the social
worker that he was experiencing anxiety before visits as well as
his statement that he felt sick to his stomach in anticipation of a
visit with mother. Further, mother continued to exhibit signs of
paranoia, had not provided proof of a neurological or
psychological evaluation, and had not signed a HIPAA release
which would have enabled the Department to verify her
statements about her participation in therapy.” (Id.)
We affirmed the juvenile court’s order.
9
E. Continued Reunification Period
1. July 29, 2025, Progress Review
On July 29, 2025, the juvenile court held a progress review
hearing. The court acknowledged its receipt of a last minute
information filed by the Department on July 17, 2025.
In the information, the social worker reported that the
child had requested a younger therapist and that since June 12,
2025, he had completed three sessions with the new therapist.
Although it was too early in the patient relationship for a
progress report, the therapist reported the child did not wish to
engage with mother and did so only because it was court-ordered.
The therapist recommended against commencing conjoint
therapy at that time due to the risk of retraumatizing the child
and disrupting the progress he had made in sister’s home.
The social worker observed that the child was resisting the
duration and frequency of his visits with mother. When told his
visits were scheduled for two hours, he responded, “‘Absolutely
not. One hour is enough.’” He canceled visits to study or to
attend a function or for no reason. While mother greeted him
warmly with affection, the child gave her limited responses and
watched videos on his phone.
During a monitored visit, mother expressed that she would
like daily visits during the child’s summer break. The child
became upset and explained to mother why past experiences with
her made it hard for him to see her. He told mother he did not
want to live with her or continue to see her weekly. The social
worker reported that the remainder of the visit went well as the
two “were more engaged and able to communicate after [the
10
child] expressed how he felt;” mother agreed to reduce her visits
to every other week.
At the progress review hearing, counsel for mother argued
to the juvenile court that mother’s concession showed her
progress in her individual therapy. Counsel requested that the
child be released to mother or, in the alternative, that the court
order conjoint counseling to begin forthwith, suggesting that the
counseling sessions occur during the alternating weeks mother
did not visit with the child. Alternatively, she asked the court to
“set a time parameter for when these counseling sessions [could]
begin.”
The child’s counsel requested that he remain suitably
placed with sister and stated that the child was not ready to
begin conjoint counseling with mother.
The juvenile court noted that mother was enrolled in
regular therapy and had signed a medical release form so that
the Department could receive updates on her attendance and
progress. The court maintained all prior orders including that
“conjoint counseling is to occur once deemed appropriate by the
child’s individual therapist.” The court also ordered the
Department to provide an update from the therapist on conjoint
counseling.
2. August 26, 2025, Status Review Report
In the August 26, 2025, status review report, the
Department reported that mother was renting a room in an
apartment with three roommates. Mother claimed her
roommates looked through her personal belongings, opened her
mail, stole her paychecks, and broke her prescription eyeglasses.
11
Mother’s medical records documented that mother
experienced brief, involuntary, and irregular movements of her
head, neck, and right shoulder that she did not acknowledge.
She also appeared to have “mild difficulty with comprehend[ing]
… the social world” and communicating with others. She began
but did not complete the neurological assessment ordered by the
court.3 The social worker added that mother completed a
psychiatric evaluation on December 30, 2024, at which time she
was prescribed a medication for mood and anxiety.
The social worker reported mother did engage in some
therapy to manage her mood and anxiety and build “healthy
coping skills.” She attended 11 sessions between January and
August 2025, five of which occurred after the April 29, 2025, six-
month review hearing. The social worker advised that mother
“minimally demonstrate[d] new skills and behaviors consistent
with [her] case plan objectives[,]” and although she was
participating in mental health services, she did not take
responsibility for her actions or understand why the Department
was involved with her family. She appeared confused about the
social worker’s role, had difficulty remembering to whom she had
spoken, reported not having contact with the social worker
despite speaking with him numerous times, and randomly
appeared in the Department’s lobby and created issues with the
3 When the juvenile court sustained the section 300 petition,
it ordered mother to undergo a neurological evaluation. At the
six-month review hearing held on April 29, 2025, mother had not
completed the neurological evaluation. As of the time the section
366.21, subdivision (f) report was drafted in August 2025, mother
had seen a neurologist and completed the blood work but not the
24-hour urine sample and refused the MRI the neurologist
ordered for her.
12
staff. The social worker also observed that mother had mental
health needs and possible cognitive and/or neurological issues
that were contributing to her lack of insight and progress.
According to the social worker, the child was thriving in
sister’s care. He did not want to return to mother’s care and
claimed he would run away if returned to her. He wanted sister
to adopt him.
Mother and the child continued to visit on a monitored
basis every other week. The child believed the juvenile court was
forcing him to visit mother and described the visits as “‘okay.’”
He reported that conversations with mother overwhelmed him
because she talked about her financial problems and he felt
stressed and helpless. And he continued to have difficulty
overcoming the trauma he suffered in mother’s care. He also
disclosed that he suffered from alcohol addiction between July
2023 and September 2024, while living with mother, but had
remained sober in sister’s care.
Initially, the child was not receptive to individual therapy
but came to believe he was benefiting from it. The child reported
not wanting to participate in conjoint counseling with mother
because it would disrupt the progress he had made with his
mental health. His therapist told the social worker that she
agreed starting conjoint therapy at that point could retraumatize
the child. The social worker acknowledged mother’s efforts in
visiting the child and engaging in mental health services and
recommended additional reunification services.
3. September 15, 2025, Last Minute Information
In a September 15, 2025, last minute information, the
social worker reported that the Department continued to assist
13
mother with housing and mental health care.4 Mother’s new
therapist, who had been treating mother since July 2025,
reported mother had difficulty following boundaries, was not
oriented to time, mixed up the appointment dates, and showed up
in the office to complain despite being informed that the office
was not available for walk-in services. The therapist believed
mother should be referred to county therapeutic health services
to obtain more intensive care through Medi-Cal coverage. The
social worker coordinated with mother’s case manager at Kaiser
to oversee the transfer of mother’s care. (See supra, fn. 4.)
Mother continued to demonstrate severe mental health
issues during the period of supervision. She exhibited symptoms
of paranoia, including reporting that someone was tampering
with her cell phone, following her, and “watching her every
move,” including spying on her during visits with the child. She
reported having gone to the police regarding her roommates and
the people allegedly following her. Mother threatened to sue the
Department for wrongfully detaining the child. She continued to
be confused by his removal from her custody and the restraining
orders preventing her from contacting sister or the maternal
grandmother.
Mother and the child continued to visit every other week.
The child said mother’s mental health was a barrier to them
forming a bond or attachment and he would not feel safe if he
were returned to her care. He was frustrated that he was forced
4 Mother’s specialty mental health care services were
transferred from Kaiser to the county in September 2025. The
new facility attempted to contact mother, but she did not answer
the phone. The social worker contacted mother and advised her
to contact the facility.
14
to converse with mother when she was unable to comprehend
reality. He said any questions about or references to his past
traumatic experiences living with mother were “triggering” and
caused him anger and anxiety. He was adamant that he would
not return to mother’s custody even if the juvenile court ordered
him to do so.
F. Twelve-Month Status Review Hearing
At the September 16, 2025, 12-month status review
hearing, the juvenile court acknowledged that the child was doing
well in the care of sister. It also noted that the child’s therapist
remained unable to recommend conjoint counseling with mother.
Mother requested that the child be returned to her care.
Alternatively, she requested unmonitored visits with the child
and a “no reasonable services finding due to [mother] and [the
child] still not participating in conjoint counseling.”
The child requested that reunification services be
terminated immediately. His counsel argued that mother’s
mental health issues would not be resolved in the near future and
that it was “difficult to see how [the child could] be safely
returned to her care.” He asked that visits with mother be
limited to twice a month.
The juvenile court found that it would be detrimental to
return the child to mother’s custody but continued reunification
services. It found mother was in substantial compliance with the
case plan because she consistently visited the child, made
significant progress in resolving her mental health issues, and
demonstrated the capacity and ability to complete the objectives
of the treatment plan. The court also found that there was “a
15
substantial probability” that the child would be returned to her
custody and care within the next six months.
The juvenile court declined to make a no reasonable
services finding. It found that it was not in the child’s best
interest to force him to participate in conjoint counseling against
the recommendation of his therapist. The court ordered the
Department to actively assist mother with housing, employment,
and mental health services enrollment. And it set a progress
review hearing in three months to address the possibility of
starting conjoint counseling and liberalizing mother’s visits to
unmonitored status.
Mother timely filed a notice of appeal.
III. DISCUSSION
When a finding that reunification services were adequate is
challenged on appeal, we review it for substantial evidence
according to the circumstances of the particular case. (In re
Taylor J. (2014) 223 Cal.App.4th 1446, 1451; In re Alvin R. (2003)
108 Cal.App.4th 962, 971.)5 For services to be deemed adequate,
5 The remedy for a failure to provide reasonable reunification
services is not reunification but an order for the continued
provision of services, which is the order the juvenile court made
in this case. (In re Alvin R., supra, 108 Cal.App.4th at p. 975.)
As in mother’s last appeal, we will assume that mother was
aggrieved by the reasonable services finding because an
erroneous reasonable services finding could impair any section
352 request that she may make for further services at the 18-
month review hearing or lead to the erroneous termination of
parental rights. (See In re A.O. (2025) 111 Cal.App.5th 1048,
1061.) Even if she were not aggrieved, we explain, for mother’s
16
“[t]he [D]epartment must make a ‘“‘good faith effort’”’ to provide
reasonable services responsive to the unique needs of each
family.” (Mark N. v. Superior Court (1998) 60 Cal.App.4th 996,
1010 (Mark N.), superseded by statute on other grounds as stated
in Earl L. v. Superior Court (2011) 199 Cal.App.4th 1490, 1504.)
“We must view the evidence in the light most favorable to the
[D]epartment and indulge all legitimate and reasonable
inferences to uphold the order.” (Mark N., supra, 60 Cal.App.4th
at p. 1010; accord, In re Monica C. (1994) 31 Cal.App.4th 296,
306.)
Mother contends that because conjoint therapy had not
commenced during the 12-month period of family supervision, the
juvenile court’s finding that the Department provided reasonable
services is not supported by substantial evidence. Relying on In
re Alvin R., supra, 108 Cal.App.4th 962 and Patricia W. v.
Superior Court (2016) 244 Cal.App.4th 397 (Patricia W.), mother
contends that the Department and the court should have
modified the case plan so that conjoint therapy could commence
without the approval of the child’s therapist or found “an
alternative therapeutic pathway” to facilitate reunification.
According to mother, “the Department and juvenile court
maintained an order that was impossible to perform.”6
benefit, why her challenge to the finding is without merit. (In re
Alexis E. (2009) 171 Cal.App.4th 438, 451.)
6 To the extent mother contends the juvenile court should
have modified the dispositional order to remove the approval of
the child’s therapist as a prerequisite to conjoint therapy, we
addressed that argument in the prior appeal. (J.G. I, supra,
B346038 [explaining mother abandoned her appeal from the
17
In In re Alvin R., supra, 108 Cal.App.4th 962, the child was
reluctant to visit his parent. (Id. at p. 972.) Family therapy was
deemed essential to promote visitation and thus enable
reunification. (Ibid.) The juvenile court ordered conjoint
counseling but a five-month period elapsed without any type of
therapy for the child. (Ibid.) The delay was attributed to
obstacles faced by the child’s guardian in arranging his
attendance. (Id. at p. 973.) Further, the child was unwilling to
visit with father until conjoint counseling began. (Id. at pp. 967–
968.) The court of appeal found that the Department did not
make reasonable efforts to overcome the logistical obstacles and
ensure the child received therapy, e.g., by finding a therapist
closer to the child’s home or arranging transportation for the
child and therefore reversed the court’s reasonable reunification
services finding. (Ibid.) The court explained that “[c]onjoint
therapy was surely critical here. [The child] had refused
visitation for four months, and both the court and the social
worker recognized that visitation would probably not take place
without conjoint therapy.” (Id. at p. 972.)
In Patricia W., supra, 244 Cal.App.4th 397, mother suffered
from mental illness and lost custody of her child, in part, because
of her inability to stay properly medicated. (Id. at p. 422.) The
reviewing court found the Department did not meet its burden to
show that it identified mother’s mental health issues, provided
services designed to enable her to obtain appropriate medication
and treatment and stay medicated so she could safely parent.
(Ibid.)
dispositional order and did not file a request for a modification of
the order under section 388].)
18
In re Alvin R., supra, 108 Cal.App.4th 962, and Patricia W.
supra, 244 Cal.App.4th 397, are distinguishable because the
obstacles to the therapy treatment were logistical and the
juvenile court in those cases found the Department failed to work
to eliminate the obstacles. Here, where the child has suffered
significant trauma from years of living with mother’s mental
illness, the obstacle was the child’s emotional readiness, an
intangible factor beyond the Department’s control.
The Department assisted the family by providing mental
health resources to mother and child as well as monitored
visitation. The Department referred mother for psychiatric
evaluation and neurological evaluation, but the latter mother
refused to complete. The Department also referred mother to
therapy, which she attended inconsistently. Social workers
stayed in regular contact with mother and assisted her with
mental health services. The child consistently attended therapy
sessions since November 2024, and the Department provided him
with a younger therapist when requested.
As we described in our prior opinion, the disposition order
included a case plan that included conjoint counseling when
recommended by the child’s therapist. Like the prior therapist,
the child’s new therapist recommended against conjoint
counseling. Her opinion is supported by the child’s aversion to
spending time with mother as shown by his behavior during
visits and his propensity to cancel visits, and by the child’s
statements to the social worker that spending time with mother
caused him emotional trauma and that he would run away if
returned to mother’s custody. Both the therapist and the social
worker opined that returning the child to mother would have an
adverse effect on his mental health. By the time of the 12-month
19
review hearing, the child was 16 years old and well able to
articulate his feelings about his relationship with mother.
Further, mother continued to exhibit symptoms of
psychiatric and neurological illness. She showed signs of
paranoia, delusions, confusion, and a failure to understand why
the child had been removed from her care.
Mother complains that conjoint therapy had not
commenced because the child’s therapist did not believe the child
was ready, but there was “no consideration of a plan to commence
conjoint therapy between mother and [the child that] included
[mother].” She offers that “[c]onsideration of alternatives, such
as an expert assessment that included both [mother] and [the
child], could have addressed any obstacles with initiating conjoint
counseling, and looked toward a path to overcoming obstacles in
commencing conjoint counseling.” Mother, however, did not
propose an alternative case plan to the Department or the
juvenile court. She has therefore forfeited her claim that the
Department should have provided an “expert assessment.” (In re
S.B. (2004) 32 Cal.4th 1287, 1293, superseded by statute on
another ground as stated in In re S.J. (2008) 167 Cal.App.4th
953, 962; In re Lorenzo C. (1997) 54 Cal.App.4th 1330, 1338.)
On this record, the juvenile court could have reasonably
concluded that the initiation of conjoint therapy against
professional advice was not appropriate. The evidence was
substantial that contact between mother and the child distressed
the child and that forcing the child to participate in conjoint
counseling with mother could cause his mental health to
deteriorate and reverse the progress he had made. Viewing the
evidence in the light most favorable to the Department and
indulging all legitimate and reasonable inferences in favor of
20
upholding the juvenile court’s order as we must, we find that
substantial evidence supports the court’s finding that the
Department provided reasonable reunification services despite its
refusal to order the child to participate in conjoint therapy with
mother. (Mark N., supra, 60 Cal.App.4th at p. 1010.)
IV. DISPOSITION
The order is affirmed.
NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS
KIM (D.), J.
I concur:
MOOR, J.
21
In re J.G.
B349097
BAKER, Acting P. J., Dissenting
During a disposition hearing held in October 2024, the
juvenile dependency court removed minor J.G. (Minor) from
mother V.G.’s (Mother’s) custody, ordered reunification services
for Mother, and directed that Mother and Minor participate in
conjoint counseling when deemed appropriate by Minor’s
therapist. Monitored visits between Mother and Minor were also
ordered.
The juvenile court held a six-month review hearing in April
2025 and rejected an argument that the Los Angeles County
Department of Children and Family Services (DCFS) had by then
failed to provide reasonable services because it had not facilitated
commencement of the conjoint counseling the court ordered at
disposition. We rejected a challenge to that ruling on appeal,
reasoning the juvenile court reasonably concluded Minor was not
then ready to begin conjoint counseling.
This appeal is taken from the juvenile court’s ruling at the
12-month review hearing finding DCFS had provided reasonable
services even though DCFS by then still had not facilitated even
one conjoint counseling session. The juvenile court deferred to
the opinion of Minor’s therapist—though not the same therapist
Minor had at disposition because in the interim Minor had
requested and been given a new therapist—that Mother and
Minor should not engage in a joint therapy session.
In my view, the juvenile court’s reasonable services finding
finds no adequate support in the record. (In re J.P. (2017) 14
Cal.App.5th 616, 624; see also Conservatorship of O.B. (2020) 9
Cal.5th 989, 1011–1012 [discussing the substantial evidence
review when a finding is required to be made by clear and
convincing evidence].) Minor undoubtedly suffered trauma when
previously in Mother’s custody, and conjoint counseling was
ordered as an important component of attempting to mediate that
trauma and facilitate some prospect of reunification. That
conjoint counseling had not even commenced precludes a finding
that the services DCFS provided were reasonable.
Insofar as DCFS contends its efforts were reasonable
because Minor’s therapist still was not recommending conjoint
counseling at that time, there are two responses. First, it had by
then been a year since disposition, Minor’s new therapist offered
no time by which it was anticipated that conjoint counseling
could begin, and the therapist explained that further delaying
conjoint counseling was in part necessary for her own reasons—
she had been recently assigned to Minor and “there needs to be
an increased time frame to conduct a thorough assessment to
decide whether or not joint counseling with [M]other is
appropriate.” Deferring to the therapist’s opinion under these
circumstances was unsound. Second, and relatedly, throughout
the year when conjoint counseling was not occurring, monitored
visitation between Minor and Mother was. I see no reasoned
basis to conclude that conjoint counseling with Mother, Minor,
and a trained counseling professional should not be attempted
because it would be too traumatic while at the same time
enforcing visitation between Mother and Minor that was
overseen by a monitor without such professional training. In
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other words, if visitation was not too traumatizing to forgo it
entirely, the same is necessarily true for conjoint counseling.
Indeed, the available evidence suggests conjoint counseling, had
it been facilitated, may well have been productive: as the
majority recounts, at one visit when Minor expressed his feelings
and told Mother that he did not want to live with her or see her
weekly, “the remainder of the visit went well as the two ‘were
more engaged and able to communicate after [Minor] expressed
how he felt.’”
I therefore respectfully dissent from affirmance of the
juvenile court’s reasonable services finding.
BAKER, Acting P. J.
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