Filed 8/25/26 In re K.J. CA2/8
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IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA
SECOND APPELLATE DISTRICT
DIVISION EIGHT
In re K.J., et al., Persons Coming B345450
Under the Juvenile Court Law.
______________________________ Los Angeles County Superior
LOS ANGELES COUNTY Court No. 25CCJP00696A-C
DEPARTMENT OF CHILDREN
AND FAMILY SERVICES,
Plaintiff and Respondent,
v.
R.M.,
Defendant and Appellant.
APPEAL from orders of the Superior Court of Los Angeles
County, Marguerite Downing, Judge. Affirmed.
Nicole Kronberg and Jennifer Peabody, under appointment
by the Court of Appeal, for Defendant and Appellant.
Dawyn R. Harrison, County Counsel, Jacklyn K. Louie,
Assistant County Counsel, and Sarah Vesecky, Deputy County
Counsel, for Plaintiff and Respondent.
____________________
A mother challenges the juvenile court’s assumption of
jurisdiction. She claims the court’s inquiry under the Uniform
Child Custody Jurisdiction and Enforcement Act (Fam.
Code, § 3400 et seq.) (the Act or UCCJEA) was faulty and the
wrong Texas court ceded jurisdiction. She asks us to remand the
matter for a proper inquiry.
Assuming the mother did not forfeit this challenge, she has
not cleared the hurdle of harmless error.
The Act determines the proper forum to adjudicate issues
involving children subject to out-of-state custody orders. It sets
out various ways in which a court may assert jurisdiction over a
child. The Act applies to dependency proceedings. (In re Kayla
W. (2023) 97 Cal.App.5th 99, 105 (Kayla).)
The mother came from Texas to California with her three
children in the fall of 2024 after she met a man online who lived
in Lawndale. The mother did not have a permanent home in
Texas. The detention report notes she “had a long history of
homelessness with her children.” She told a social worker she
was “in multiple shelters in Texas” with her children and she did
not have help from family there. Her father reported she had
been “bouncing around San Antonio Texas” before heading to
California. On appeal, the mother concedes her family “was quite
transient.”
Over winter break, the mother briefly moved back to Texas
after her boyfriend beat her. Again, she and her children stayed
in shelters. But the family soon returned to California and the
boyfriend. With him, the mother admitted, they had a place to
stay and a dad. The oldest child reported they were living out of
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their car in Texas and came back to California “ ‘because we had
nowhere else to go.’ ”
The mother said she had no contact information for the
children’s father. She denied there were any formal custody
arrangements and denied “any referral or case history in the
state of Texas.”
The juvenile court broached the Act at the initial hearing in
March 2025. The mother gave the court the name of a town
(“Frefer”) where she “could go” in Texas. (“Freer” is in Duval
County, Texas.) The mother said she had stayed in a home there
for a year or so, at some unspecified time. Then she backtracked:
“It’s hard for me to say I can go to the house, trust father will not
remove us from this again.” She came to California “from
shelters.”
The minute order for this hearing recognizes “there may be
a UCCJEA” issue and states the court would follow up with the
state of Texas.
A social worker emailed a Texas agency “to obtain any child
abuse history” for the family in Texas. The Department
eventually learned there were investigations, but the children
never were removed from their parents.
Our record contains a letter from a Bexar County court
showing the mother’s last known address was in San Antonio,
Texas — which is in Bexar County. The letter reports court staff
searched their archives, found no responsive case, and it
appeared Bexar County had no basis for jurisdiction. This letter
was filed in this case.
At a hearing the next day, the juvenile court announced it
had reached out to “Frefer County in Texas,” which did not have
cases for this family, was not interested “in pursuing anything,”
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and was willing to let California take jurisdiction. The court
concluded “the UCCJEA issue has been addressed.” No one
objected or commented.
In April 2025, there was a brief contested jurisdiction
hearing where no party questioned the ability of the court to
assert jurisdiction under the Act.
Even assuming the mother did not forfeit her UCCJEA
challenge, her appeal fails because she has not shown a more
favorable result was likely, absent the error alleged here. (See
Kayla, supra, 97 Cal.App.5th at p. 106 [“a failure to comply with
the UCCJEA’s procedural requirements is subject to harmless
error analysis. [Citations.] The party challenging a lower court’s
ruling must therefore show it is reasonably probable a result
more favorable to the appellant would have been reached in the
absence of any error”]; see also In re A.C. (2017) 13 Cal.App.5th
661, 673–674 [reversal not required where mother made no
attempt to carry her burden on appeal to show it was reasonably
probable she would have obtained a more favorable result with
changes to the court’s UCCJEA inquiry].)
The mother concedes this harmless error analysis applies.
She assumes harm because the record shows she lived in other
parts of Texas and because Texas police and social workers
checked on the children a few times because of domestic violence
between her and the father. She posits there was reason to
believe the family had an earlier dependency history there.
This speculation is not enough, particularly coupled with
the results of the Department’s investigations into this history
and the mother’s denials about any such history and any custody
arrangements.
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DISPOSITION
We affirm the challenged orders.
WILEY, Acting P. J.
We concur:
VIRAMONTES, J.
SCHERB, J.
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