Filed 7/6/26 In re Z.B.I. CA2/8
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IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA
SECOND APPELLATE DISTRICT
DIVISION EIGHT
In re Z.B.I., a Person Coming B352112
Under the Juvenile Court Law.
______________________________ (Los Angeles County
LOS ANGELES COUNTY Super. Ct. No. 23CCJP04256)
DEPARTMENT OF CHILDREN
AND FAMILY SERVICES,
Plaintiff and Respondent,
v.
A.B.,
Defendant and Appellant.
APPEAL from orders of the Superior Court of Los Angeles
County, Linda L. Sun, Judge. Dismissed.
A.B., in pro. per; and John P. McCurley, under
appointment by the Court of Appeal, for Defendant and
Appellant.
No appearance for Plaintiff and Respondent.
_________________________
Mother A.B. appeals from juvenile court orders entered at a
January 2026 status review hearing. Only orders concerning her
child Z.B.I. are at issue. At the status review hearing, the court
retained jurisdiction over Z.B.I., ordered Z.B.I.’s continued
removal from Z.B.I.’s parents, found reunification services had
been reasonable to date, and continued reunification services. As
to the other three children, the court terminated reunification
services and began permanency planning. Mother unsuccessfully
challenged these other orders in a writ proceeding. (A.B. v.
Superior Court (Jun. 9, 2026, B352109) [nonpub. opn.].)
Mother’s counsel, following the procedure outlined in In re
Phoenix H. (2009) 47 Cal.4th 835 (Phoenix H.), submitted an
appellate brief identifying no colorable arguments for reversal.
Counsel informed mother she could seek to file a supplemental
brief, noting our obligation to allow briefing if a parent can show
“good cause that an arguable issue does, in fact, exist.” (Id. at p.
844.) Mother submitted a supplemental brief asserting three
issues. None of them, however, is an arguable issue.
First, mother contends insufficient evidence supports the
juvenile court’s reasonable services finding. She identifies no
specific facts regarding services offered or withheld prior to
January 2026 to suggest inadequacy. Arguments in a brief that
are unsupported by specific facts or citations to the record cannot
raise arguable issues on appeal. (In re Sade C. (1996) 13 Cal.4th
952, 994 [parents must “ ‘present argument and authority on
each point made’ ”]; In re S.C. (2006) 138 Cal.App.4th 396, 408
[“[A]ppellant must present meaningful legal analysis supported
by citations to authority and citations to facts in the record that
support the claim of error”].) In conjunction with this substantial
evidence argument, mother contends her case plan did not
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comply with asserted participation and signature requirements of
Welfare and Institutions Code section 16501.1. Mother has not
pinpointed these asserted requirements within the nearly 7,000
words and 90 paragraphs of the statute or addressed the nature
of these asserted requirements. She has not offered context for
the asserted noncompliance or delineated prejudice from it. The
case she cites regarding the statute, In re P.C. (2008)
165 Cal.App.4th 98, 105–108, does not cite that statute or
address case plan defects. The record, moreover, shows mother
was offered numerous opportunities to participate in the
dependency proceeding, but chose to flee California and
repeatedly stonewalled social workers.
Second, mother challenges the denial of a continuance of
the status review hearing. But mother identifies no way in which
the denial harmed her, particularly as to Z.B.I., for whom
reunification services were continued.
Third, mother questions whether the record shows
compliance with a reporting requirement of Family Code section
3410, subdivision (d), a part of the Uniform Child Custody
Jurisdiction and Enforcement Act. “A court of this state may
communicate with a court in another state concerning a
proceeding arising under this part.” (Fam. Code, § 3410, subd.
(a).) Generally, “a record must be made of a communication
under this section.” (Id., subd. (d).) Mother notes a minute order
from the January 30, 2026, hearing in which the juvenile court
noted it had “spoken to Judge Brian Palmer from Arizona and
inform[ed] [the] parties that Arizona cedes jurisdiction to this
Court.” The reporter’s transcript from that hearing documents
that communication in greater detail. Mother points to no
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authority suggesting more was required. (Cf. In re C. T. (2002)
100 Cal.App.4th 101, 111–112.)
In sum, mother presents no arguable issue regarding the
orders on appeal, and we therefore dismiss the appeal. (Phoenix
H., supra, 47 Cal.4th at pp. 844, 846.)
DISPOSITION
We dismiss the appeal.
SCHERB, J.
We concur:
STRATTON, P. J.
WILEY, J.
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