In re J.J. CA2/7

Filed 8/19/26 In re J.J. CA2/7
NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS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
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IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION SEVEN

In re J.J. et al., Persons Coming B346807
Under the Juvenile Court Law.
(Los Angeles County
Super. Ct. No. 24LJJP00359A-B-
C)

LOS ANGELES COUNTY
DEPARTMENT OF CHILDREN
AND FAMILY SERVICES,

Plaintiff and Respondent,

v.

LATRICIA M.,

Defendant and Appellant.

APPEAL from an order of the Superior Court of
Los Angeles County, Stephanie M. Davis, Judge. Dismissed.
Janette Freeman Cochran, under appointment by the Court
of Appeal, for Defendant and Appellant.
Dawyn R. Harrison, County Counsel, Kim Nemoy,
Assistant County Counsel, and Tracey Dodds, Deputy County
Counsel, for Plaintiff and Respondent.
________________________

INTRODUCTION

Mother Latricia M. appeals from the juvenile court’s
jurisdiction findings and disposition orders declaring her three
children dependents of the court pursuant to Welfare and
Institutions Code section 300.1 Mother contends there was
insufficient evidence of harm or potential harm to support the
juvenile court’s findings that Mother lacked the ability to
adequately parent and provide for her children and that Mother
failed to address one of her child’s mental health challenges,
thereby placing the other children at risk of harm. While her
appeal was pending, the juvenile court terminated jurisdiction.2
Because we cannot grant Mother effective relief, we dismiss her
appeal as moot.

1 Unspecified statutory references are to the Welfare and
Institutions Code.
2 We grant the Department’s motion for judicial notice of the
termination orders. (Evid. Code, §§ 452, subd. (d), 459.)

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FACTUAL AND PROCEDURAL BACKGROUND

A. Dependency Proceedings
Mother has three children, J.J. (born 2009), Jhk.J. (born
2010) and Jhr.J. (born 2013). On October 15, 2024, Mother made
a call to a child protection hotline asking for removal of J.J. and
Jhk.J. from her care because she was “in fear for her life” after
being “physically, mentally and verbally abused by [the]
children,” and any attempts at discipline were met with physical
resistance. (Emphasis omitted.)
Between September 2023 and October 2024, law
enforcement had previously been called to Mother’s home nine
times in response to reported disorderly behavior by J.J. and
Jhk.J. These events included one instance where J.J. ran away
from home and eight instances stemming from Jhk.J.’s mental
health challenges, including suicidal statements and gestures,
physical attacks on the family, and destruction of property at the
home. Several calls to law enforcement were made by Mother
because she stated she felt “overwhelmed.” On October 18, 2024,
Jhk.J. assaulted Mother. Mother subsequently called law
enforcement and asked if law enforcement could “send [Jhk.J.] to
a facility to get . . . him psychologically evaluated.” Jhk.J. was
“placed on a . . . psychiatric hold at Olive View Medical Center.”
After conducting an evaluation, the medical center’s mental
health evaluation team reported it did not “find anything wrong
with [Jhk.J.]” and could not hold him. Mother subsequently took
Jhk.J. to therapy.
On November 4, 2024, the Los Angeles County Department
of Children and Family Services (Department) filed a petition
pursuant to section 300, subdivisions (b) and (j). The petition

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alleged J.J. and Jhk.J. suffered from “mental, emotional, and
behavioral problems, including but not limited to aggressive and
assaultive behavior” and that Mother lacked the ability to
provide adequate parental care and supervision of the children,
placing all the children at risk of serious harm or danger.
On November 19, 2024, the court held a detention hearing
on the section 300 petition.3 The court found the existence of a
prima facie case on the section 300 petition. The court ordered
the release of the children to Mother subject to Jhk.J. remaining
in therapy and the Department social worker making
“unannounced” visits to the home.
On January 16, 2025, a social worker for the Department
interviewed several family members, including the maternal
grandmother, maternal aunt, maternal great aunt, and Mother’s
ex-boyfriend. All gave positive reviews of Mother’s parenting and
stated Mother was a good parent. The maternal grandmother
also stated “she did not know why [Mother] was being
investigated.”
The court conducted the jurisdiction and disposition
hearing over several days. At the hearing on February 7, 2025,
minors’ counsel argued the children believed that the case could
be resolved without court or Department intervention, felt very
well taken care of by Mother, and asked for termination of
dependency jurisdiction. The court heard from Mother regarding
her frustrations with the “abrupt” visits from the social worker
and her disagreement with the Department’s November 18, 2024
detention report. The court declined to stop the unannounced

3 There are three fathers. They are not parties to this
appeal. We therefore limit our discussion of facts and findings to
those most relevant to Mother.

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visits from the social worker but agreed Mother needed help with
her sons’ behavioral issues. The court explained, “I am saying
exactly the same thing you are saying; that there were behavioral
issues that you were finding difficult to deal with. You asked
DCFS for help.”
In an April 8, 2025 progress report, the Department stated
Mother had found a mentor for her children, but the mentor
subsequently moved and a replacement had not been identified.
The Department reported Mother was provided with resources
including a program to help teach her parenting skills and
contact for a psychiatric mobile response team. The report stated
Mother “ha[d] not made any effort to utilize [the] provided
resources.”
At the continued jurisdiction and disposition hearing,
Mother’s counsel asked the court to dismiss the case because it
stemmed from two mental health incidents involving Jhk.J.
These incidents led to assessments, therapy, and placement in
sports for Jhk.J., which improved his overall mood and behavior
to a manageable stability. The juvenile court noted all three
children were “extremely polite, respectful, and articulate . . . all
to the mother’s credit,” but it stated J.J. had been parentified, in
part, due to Mother “focusing everything on [Jhk.J.] and not
providing services for herself or the other children.” The court
found that because Mother failed to seek treatment for herself,
J.J., and Jhr.J., and did not pursue referrals given to her by the
Department, there was sufficient evidence for the children to be
declared dependents under section 300.
The juvenile court amended the petition to add the word
“substantial” in front of “risk” as to each count so that it found
Mother’s conduct “plac[ed] the children . . . at substantial risk of

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serious physical harm, damage, and danger,” and it sustained the
petition as amended. The court ordered the Department to
provide family maintenance and therapy services for Mother,
including parenting classes, individual counseling, and conjoint
counseling. The court released all three children to Mother’s
custody under the Department’s supervision.
Mother timely appealed from the jurisdiction findings and
disposition order.
On October 24, 2025, while this appeal was pending, the
juvenile court terminated jurisdiction and released the children
to Mother’s custody. Mother did not appeal from the termination
orders.

DISCUSSION

A. Mootness and Dependency Appeals
“A case becomes moot when events ‘ “render[ ] it impossible
for [a] court, if it should decide the case in favor of plaintiff, to
grant [the plaintiff] any effect[ive] relief.” ’ [Citation.] For relief
to be ‘effective,’ two requirements must be met. First, the
plaintiff must complain of an ongoing harm. Second, the harm
must be redressable or capable of being rectified by the outcome
the plaintiff seeks.” In other words, “relief is effective when it
‘can have a practical, tangible impact on the parties’ conduct or
legal status.’ [Citation.] It follows that, to show a need for
effective relief, the plaintiff must first demonstrate that he or she
has suffered from a change in legal status.” (In re D.P. (2023)
14 Cal.5th 266, 276-277 (D.P.).) “An order terminating juvenile
court jurisdiction generally renders an appeal from an earlier
order moot.” (In re Rashad D. (2021) 63 Cal.App.5th 156, 163

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(Rashad D.).) “However, dismissal of a dependency appeal for
mootness following termination of jurisdiction ‘is not automatic,
but “must be decided on a case-by-case basis.” ’ ” (Id. at p. 163.)
Even when a case is moot, however, the reviewing court
generally has “ ‘inherent discretion’ ” to reach the merits of an
appeal. (D.P., supra, 14 Cal.5th at p. 282.) The reviewing court
generally will exercise that discretion when a case involves an
issue of broad public interest that is likely to recur, when the
controversy between the parties may recur, or when a material
question remains for the court’s determination. (See ibid.) The
California Supreme Court in D.P. identified several other factors
for courts to consider in deciding whether discretionary review of
a moot case is appropriate. (Id. at pp. 284-286.) First, the court
may consider whether a challenged jurisdiction finding could
impact current or future dependency proceedings, for example, by
influencing a child protective agency’s decision to file a new
dependency petition or a juvenile court’s determination about
further reunification services. (Id. at p. 285.) Second, the court
may consider the allegations against the parent because “[t]he
more egregious the findings against the parent, the greater the
parent’s interest in challenging such findings.” (Id. at p. 286.)
Third, the court may consider whether the case became moot
because a parent promptly complied with his or her case plan: “It
would perversely incentivize noncompliance if mootness doctrine
resulted in the availability of appeals from jurisdictional findings
only for parents who are less compliant or for whom the court has
issued additional orders.” (Ibid.)

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B. Mother’s Appeal Is Moot
1. The Appeal Is Moot Because the Juvenile Court
Terminated Jurisdiction
Mother argues the evidence did not support the juvenile
court’s finding that she lacked insight regarding Jhk.J.’s mental
health challenges and that she failed to supervise or protect J.J.,
Jhk.J. and Jhr.J. from a substantial risk of serious physical
harm. We decline to address the issues raised by Mother because
her appeal is moot. The juvenile court’s termination orders
render it impossible to grant Mother any effective relief. The
children have remained in her custody. Under these
circumstances, “the jurisdictional findings are not the basis of
any current order that is adverse to [Mother].” (In re N.S. (2016)
245 Cal.App.4th 53, 61.)
The appeal is also moot because Mother did not appeal
from the termination orders. (See In re Gael C. (2023)
96 Cal.App.5th 220, 225 [“ ‘in most cases ... for this court to be
able to provide effective relief, the parent must appeal not only
from the jurisdiction finding and disposition order but also from
the orders terminating jurisdiction and modifying the parent’s
prior custody status’ ”]; Rashad D., supra, 63 Cal.App.5th at
p. 164 [“to the extent an appellant argues, as here, that the
challenged jurisdiction finding resulted in an adverse juvenile
custody order . . ., an appeal from the orders terminating
jurisdiction and awarding custody is necessary”].)

2. No Exception to the Mootness Doctrine Applies
Mother argues exceptions to mootness apply. Relying on In
re S.R. (2025) 18 Cal.5th 1042 (S.R.), Mother suggests she “may
be” included in the Child Abuse Central Index (CACI; Pen. Code,

8
§ 11170) pursuant to the Child Abuse and Neglect Reporting Act
(CANRA; Pen. Code, § 11164 et seq.). The California Supreme
Court held in S.R. that “a parent’s appeal from a juvenile court’s
jurisdictional finding survives a mootness challenge where the
parent shows that an agency must report the allegation
underlying the court’s finding for inclusion in the CACI.” (S.R.,
at p. 1048.) S.R. stated that a case is not moot “where it is
undisputed that the allegations trigger a reporting
requirement.”4 (Id. at p. 1054.) In S.R., the Department
conceded it was required to report the mother’s physical abuse for
inclusion in the CACI. (Ibid.) S.R. contrasted its facts with those
in D.P., “where the agency represented that the allegations were
not reportable.” (S.R., at p. 1054.) D.P. found the father had “not
shown that the general neglect allegation against him was
reported for inclusion in the CACI, nor has he shown that this
type of allegation is reportable. These two layers of uncertainty
render Father’s CACI claim too speculative to survive a mootness
challenge.” (D.P., supra, 14 Cal.5th at p. 280.)
This court recently considered similar facts in In re
Landon M. (2026) 121 Cal.App.5th 686 (Landon M.). In
Landon M., the mother appealed from the jurisdiction findings
and disposition order declaring her children dependents of the
juvenile court. The court sustained allegations that the father
brandished a weapon at a cashier while the mother and the
children were in the store and then led the police on a high-speed
chase with the younger child buckled into a car seat in the back
of the vehicle. The juvenile court sustained a failure to protect

4 S.R. left open the question of whether an appeal is moot if
“a parent shows the conduct at issue is likely but not
indisputably reportable.” (S.R., supra, 18 Cal.5th at p. 1054.)

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allegation against the mother on the ground she knew the father
possessed guns but allowed him unlimited access to the children.
(Id. at p. 689.) While the mother’s appeal was pending, the
juvenile court terminated its jurisdiction and granted the mother
sole legal and physical custody. (Id. at p. 690.)
Applying S.R. and D.P., Landon M. held the mother’s
appeal was moot for two reasons: (1) neither the mother nor the
father appealed from the termination order, and (2) the
challenged jurisdiction order did not form the basis for an order
that continued to impact the mother’s rights after termination.
(Landon M., supra, 121 Cal.App.5th at p. 694.) Like Mother in
this case, the mother in Landon M. argued her appeal was not
moot because the juvenile court’s findings “subject” her to
inclusion in the CACI. (Ibid.) Landon M. rejected that argument
because “[t]he facts in this case are more similar to those in D.P.
than S.R.” That is, the mother had not shown the Department
actually reported her for inclusion in the CACI. And if the
Department had done so, mother would have received a notice of
the report but the record did not contain any such notice. (Id. at
p. 696; see Penal Code § 11169, subd. (c).) Additionally, the
mother had not shown her conduct constituted “child abuse” or
“severe neglect” as defined in CANRA. (Ibid.) Further, “the
criteria for a CACI listing based on ‘child abuse or severe neglect’
under CANRA generally appear to be narrower than the grounds
for juvenile dependency jurisdiction under . . . section 300.” (S.R.,
supra, 18 Cal.5th at pp. 1056-1057.)
Here, the facts also more closely align with those in D.P.
rather than S.R. As in D.P., the Department does not argue it is
required to report Mother for inclusion in the CACI. Nor has
Mother met her burden to show her conduct either has been

10
reported or was required to be reported for inclusion in the CACI.
First, Mother failed to show the section 300 allegations amounted
to “child abuse” or “severe neglect” that must be reported under
CANRA. As explained in Landon M., “CANRA defines ‘ “child
abuse” ’ as ‘physical injury or death inflicted by other than
accidental means upon a child.’ (Pen. Code, § 11165.6.) ‘ “Severe
neglect” ’ is defined as either (1) ‘the negligent failure . . . to
protect the child from severe malnutrition or medically diagnosed
nonorganic failure to thrive’ or (2) ‘those situations of neglect
where any person having the care or custody of a child willfully
causes or permits the person or health of the child to be placed in
a situation such that their person or health is endangered as
proscribed by [Penal Code] section 11165.3.’ (Id., § 11165.2,
subd. (a).) Penal Code section 11165.3, as relevant here,
similarly defines ‘ “the willful harming or injuring of a child or
the endangering of the person or health of a child” ’ to mean ‘a
situation in which any person . . . having the care or custody of
any child, [willfully causes or permits the person or health of the
child to be placed in a situation in which his or her person or
health is endangered.].’ ” (Landon M., supra, 121 Cal.App.5th at
pp. 696-697.)
Unlike the mother in S.R., Mother did not have physical
altercations with her children. Indeed, she was afraid of Jhk.J.’s
escalating aggression and called law enforcement. The record
reflects that Mother did not use physical force against the
children. In short, Mother’s conduct did not amount to “child
abuse” or “severe neglect.” (See S.R., supra, 18 Cal.5th at
p. 1144.) At worst, Mother’s conduct rises to the level of general
neglect, as Landon M. explains. “ ‘ “General neglect,” ’ which is
not reportable in the CACI, is defined as ‘the negligent failure of

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a person having the care or custody of a child to provide adequate
food, clothing, shelter, medical care, or supervision where no
physical injury to the child has occurred but the child is at
substantial risk of suffering serious physical harm or illness.’
(Pen. Code, § 11165.2, subd. (b), italics added; see § 11169,
subd. (a) [agency ‘shall forward’ a report of every case of ‘known
or suspected child abuse or severe neglect that is determined to
be substantiated, other than cases coming within subdivision (b)
of Section 11165.2’ (italics added)].)” (Landon M., supra,
121 Cal.App.5th at p. 697.) Mother’s failure to protect or
supervise her children from Jhk.J.’s mental health challenges is
less endangering than the mother’s failure to protect in
Landon M. Under these circumstances, Mother’s “CACI claim
[is] too speculative to demonstrate a specific legal consequence
that a favorable judgment could redress.” (D.P. at p. 282.)
Second, there is no report or statement in the record from
the Department that mentions Mother being issued a CACI
notice, as general neglect is not reportable by CACI under Penal
Code section 11169. As in Landon M., the record does not
contain a notice the Department reported Mother for inclusion in
the CACI. (See Pen. Code, § 11169, subd. (c) [when an agency
forwards a report of suspected child abuse or severe neglect to the
California Department of Justice, it “shall also notify in writing
the known or suspected child abuser that he or she has been
reported to [the CACI]”]; D.P., supra, 14 Cal.5th at p. 279;
Landon M., supra, 121 Cal.App.5th at p. 696.) Nor did Mother
state she received such notice.
Next, Mother also contends her appeal is not moot because
“[a]lthough [Mother] retains the same parental rights that she
had before filing of the section 300 petition, the sustained

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allegations are a blot on her record. The section 300 findings
could have consequences for [her] beyond jurisdiction,” citing In
re Drake M. (2012) 211 Cal.App.4th 754 (Drake M.), disapproved
on another ground in In re N.R. (2023) 15 Cal.5th 520. But
Mother does not explain what other consequences, aside from the
potential report to CACI, she would suffer. In Drake M., the trial
court made detention findings against both the mother and
father. As to the father, the Department alleged he abused
marijuana, which made him unable to supervise or protect the
child. The father argued his appeal was not moot even though
the mother did not appeal the findings against her. (Id. at
p. 762.) Drake M. explained, “Here, the outcome of this appeal is
the difference between father’s being an ‘offending’ parent versus
a ‘non-offending’ parent. Such a distinction may have far-
reaching implications with respect to future dependency
proceedings in this case and father’s parental rights. Thus,
although dependency jurisdiction over [the child] will remain in
place because the findings based on mother’s conduct are
unchallenged, we will review father’s appeal on the merits.” (Id.
at p. 763.)
By contrast, in this case Mother has not explained what
potential adverse harms or consequences follow from the
jurisdiction findings. Further, as Mother correctly notes, she has
“retain[ed] the same parental rights.” Mother has not
demonstrated ongoing harm or that an appeal would provide her
with meaningful relief since the children have remained in her
custody.
Finally, Mother’s appeal does not present circumstances
that generally warrant discretionary review of a moot case, such
as an issue of broad public interest that is likely to recur or a

13
material question that remains for the juvenile court’s
determination.

DISPOSITION

The appeal from the jurisdiction findings and disposition
orders filed by Mother on June 6, 2025 is dismissed as moot.

MARTINEZ, P. J.

We concur:

SEGAL, J. STONE, J.

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