Filed 8/10/26 In re C.J. CA1/5
NOT TO BE PUBLISHED IN OFFICIAL REPORTS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 This opinion has not been certified for publication or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

FIRST APPELLATE DISTRICT

DIVISION FIVE

In re C.J., a Person Coming Under
the Juvenile Court Law. A176348
___________________________________
SAN FRANCISCO HUMAN (City & County of San Francisco
SERVICES AGENCY, Super. Ct. No. JD23-3153B)

Plaintiff and Respondent,
v.
M.T.,
Defendant and Appellant.

M.T. (mother) appeals from the juvenile court’s order terminating
reunification services with respect to C.J. (Chanel), one of her nine children,
and setting her matter for a permanent plan and placement following a
contested 18-month review hearing under Welfare and Institutions Code
section 366.22.1 Mother contends that the court erred in terminating
reunification services because respondent San Francisco Human Services
Agency (Agency) did not provide her with reasonable services. We disagree
and affirm.

1 All statutory references are to the Welfare and Institutions Code

unless otherwise specified.

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 I. BACKGROUND
The juvenile dependency proceedings below involved eight of mother’s
nine children: Maya (born in 2005), Naeyah (born in 2007), Chanel (born in
2009), Shantel (born in 2010), Nicholas (born in 2011), Nathaniel (born in
2013), Philecia (born in 2015), and Jasiah (born in 2018). All children except
for Maya and Naeyah will collectively be referred to as “minors.”2 As this
appeal concerns only Chanel, our references to the other seven children are
limited.
A. Original Petitions and Detention
On May 10, 2023, the Agency filed two juvenile dependency petitions.
(§ 300.) The first one was filed on behalf of then 17-year-old Maya, then 16-
year-old Naeyah, then 14-year-old Chanel, then 12-year-old Shantel, then 11-
year-old Nicholas, then 9-year-old Nathaniel, and then 7-year-old Philecia.
The second one was filed on behalf of then five-year-old Jasiah. The first
petition only sought to detain Naeyah and alleged that mother and Naeyah
got into a verbal and physical altercation, during which mother “ ‘yanked’
[Naeyah’s] arm and hit her with a belt.” Mother also encouraged Naeyah’s
siblings to hit her.
The petition further alleged that mother and N.J., the alleged father of
all of the children except Jasiah, had “an extensive history of intimate
partner violence” and that N.J. had “a history of being physically violent
towards the mother . . . in the presence of the minors.” N.J. was incarcerated
at the time.3 Naeyah was placed in foster care while the other seven children
remained with mother.
At the detention hearing, the juvenile court issued a detention order as

2 Mother’s ninth child was now an adult over the age of 18.

3 References to N.J. are limited as he is not a party to this appeal.

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to Naeyah only. Counsel was appointed for all eight children. The court
placed Naeyah in foster care and granted mother supervised visitation when
Naeyah was ready and granted Naeyah visitation with her siblings.
B. Jurisdiction/Disposition Proceedings
The Agency’s July 2023 disposition report summarized its interview
with mother, who confirmed that she used a belt to discipline Naeyah but
denied physically disciplining any of her other children. Naeyah, Maya,
Chanel, and Jasiah all recalled incidents of domestic violence between J.K.
(the alleged father of Jasiah) and mother. Naeyah stated that she and her
siblings had witnessed J.K. choking mother and slamming her onto the
ground. Mother denied that J.K. ever hit her in the children’s presence or
that their arguments should be characterized as domestic violence. Mother
stated that she experienced abuse and neglect in her childhood and witnessed
extensive domestic violence. Mother’s case plan included that she care for
her children in a violence-free environment and not use physical discipline.
The Agency recommended that mother participate in family therapy with
Naeyah as well as individual therapy.
In August 2023, the Agency filed an addendum report detailing its
interview with J.K., who was incarcerated at the time. J.K. denied any
domestic violence between him and mother and claimed that they only had
“verbal disagreements.” The Agency was nonetheless concerned about the
children’s physical and emotional well-being due to their exposure to ongoing
domestic violence.4 It further noted “instances where [mother] terminated
interviews with the children when asked about violence in the home.” The

4 On August 29, 2023, the juvenile court granted mother’s request for a

temporary restraining order (TRO) against J.K. that protected both her and
her minor children. The TRO expired in December 2023.

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Agency recommended that the juvenile court declare the eight children
dependents of the court, and that all children except for Naeyah remain with
mother. The Agency subsequently filed amended petitions that struck a prior
allegation made under section 300, subdivision (b)(3).
At the jurisdiction and disposition hearing, the juvenile court sustained
the amended petitions and declared all of the children except for Maya
dependents of the court.5 The court ordered that Naeyah be placed in foster
care while the other children remain with mother. It further ordered the
Agency to provide family maintenance and reunification services as to
Naeyah, including individual therapy for mother and family therapy for
mother and Naeyah.
C. Six-Month Status Review and Section 387 Petitions
In its May 2024 six-month status review report, the Agency
recommended an additional six months of family maintenance and
reunification services for mother. The report noted that J.K. had been to
mother’s home on several occasions but was not living there. According to
mother, he had come by to pick up personal belongings but was not allowed
inside when the children were present. The report continued that there was
a concern about Nicholas’ and Shantel’s hygiene due to a nonfunctional
shower. Mother did not allow the social worker entry into her home and
declined support to address maintenance issues at her home. The report also
detailed a recent argument between mother and Nicholas where mother
“made verbal threats to kick [him] out of the home.” The social worker
referred mother and Nicholas to Family Mosaic Project (Family Mosaic) so
they could “work on their communication and other relationship needs.”

5 The amended petition was dismissed as to Maya presumably because

she reached the age of 18 by then.

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Mother was upset by this referral and told the social worker that she “[did]
not want to be bothered” and did not have the time.
Mother began individual therapy but did not start family therapy
because neither she nor Naeyah were willing to engage in it. The Agency
noted it would “re-submit [the] referral in hopes they both will come to
agreement to begin therapeutic services.” It further concluded that mother
was unwilling to accept services and that minors were at risk of “further use
of excessive discipline in the form of violence.” The Agency recommended
further “services to monitor that minors receive appropriate educational
support, routine medical services, and are attending school regularly.” The
six-month review hearing was subsequently continued several times.
On September 4, 2024, the Agency filed supplemental petitions under
section 387, asserting that minors’ placement with mother was no longer
appropriate. The petitions alleged that two days earlier, mother was arrested
after she grabbed a knife and threatened Nicholas because he was bothering
her. The petitions further alleged that mother refused to meet with the social
worker and had not utilized any family maintenance and reunification
resources or the Family Mosaic referral. The juvenile court ordered minors
detained and placed in foster care. Mother was granted supervised
visitation, subject to a criminal protective order that was issued.6 The court
then vacated the previously set six-month review hearing date and renewed
its detention findings.
The Agency’s section 387 disposition report highlighted that mother
was at risk of eviction due to over a year of unpaid rent and that “[a]t the

6 It is not clear from the record who the protective order was supposed

to protect but the Agency’s subsequent disposition report noted that the order
was “protecting minors from their mother.”

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time of removal, the home was “extremely cluttered” and “hazardous due to
cleanliness.” The Agency further noted that mother “ha[d] continued to
exhibit a tendency to minimize concerns raised” regarding minors as well as
“a lack of awareness regarding the potential consequences of her actions on
the children’s well-being.” Mother was unwilling to engage in services or
reunify with Naeyah. Mother had started a parenting class as part of her
criminal pre-trial diversion program. In addition to the parenting class and
individual therapy, the Agency recommended that mother engage in family
therapy to “foster a healthier family dynamic” and complete a psychological
evaluation.
Mother did not appear at Naeyah’s 12-month review hearing in
November 2024, and the juvenile court terminated her reunification services
without objection. At the contested section 387 hearing, the court found the
allegations in the petitions true. It ordered that reunification services
continue as previously ordered (family therapy and individual therapy), with
the addition that mother undergo a substance abuse assessment and a
psychological evaluation. The court also ordered supervised visitation once a
week (at a minimum) and set the six-month review hearing for May 2025.
D. Combined Six-Month and 12-Month Review
Before the six-month review hearing, the Agency filed a status review
report recommending that minors’ dependency status be renewed and that
mother be provided an additional six months of reunification services.
Mother had completed her parenting class, enrolled in another parenting
class, and completed her psychological evaluation. The evaluation revealed
that mother was at risk of developing a drug addiction, so the Agency
recommended that mother complete a substance abuse assessment and a

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psychiatric evaluation for medication assessment, and submit to random
drug testing.
Mother was participating in weekly individual therapy but had “not
adequately addressed the core safety concerns that led to the [Agency’s]
involvement.” Although referrals were made, family therapy had not begun
because the Agency was focused on stabilizing minors’ “care, behaviors,
education, medical and dental needs.” Minors were seeing individual
therapists to address their mental health needs. Chanel, Shantel, Nathaniel,
Philecia, and Jasiah were each assigned a Court Appointed Special Advocate
(CASA), and, for additional support, a Court Appointed Family Engagement
Specialist was appointed for all of the children.
The supervised visits began in Antioch. The Agency provided
transportation for all six children (including Chanel) from three different
homes every week and gave mother funds so she could travel to and from
Antioch. Mother did not miss a visit but sometimes arrived over half an hour
late. There was a concern that some minors were sad or cried during or after
the visits because mother gave Jasiah preferential treatment. During one
visit, “Nicholas and Nathaniel got into physical altercations that [mother]
had difficulty . . . de-escalating.” The six-month review hearing was
subsequently continued several times to October for a combined six- and 12-
month review hearing.
In October 2025, the Agency filed a status review report recommending
that mother be provided another six months of reunification services. The
Agency noted it had made a referral to Foster Care Mental Health for
therapeutic visitations and family therapy in May 2025. In March or May, it
referred minors (including Chanel) to wraparound services with Seneca
Family of Agencies (Seneca), an outside nonprofit agency. Seneca approved

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the services in June and as of August, was “working towards assigning a
team of clinicians” for minors. After finally being allowed entry into mother’s
home, the social worker observed that “the home continues to need repairs
and deep cleaning.” Mother “did not have a timeline of when further repairs
[would] be scheduled.”
Since the Agency’s last report, mother enrolled in new parenting
classes “to further . . . address parenting her teens.” Mother, however, had
difficulty implementing the parenting skills she learned, particularly when
Nicholas and Shantel got into physical altercations. Mother also lacked
“coping skills in managing stress,” which “impact[ed] her ability to respond
effectively to the minors’ needs.” During one supervised visit in September
2025, mother provided Jasiah, Philecia, and Nathaniel with electronic devices
without notifying the Agency, in direct violation of the juvenile court’s order
permitting only supervised contact with minors. When the social worker
raised the issue, mother responded that she had “the right to provide such
items to her children in order to maintain sibling communication.” Mother’s
therapist reported that mother was “actively working on her parenting skills”
but still had “not adequately addressed the core safety concerns” that led to
the Agency’s involvement. Ultimately, the Agency recommended that “the
family be given an opportunity to continue to work towards reunification and
further assess progress with long awaited therapeutic services in place.”
Finally, mother was a “no show” for all 12 random drug testing
appointments referred by the Agency during the reporting period. Mother
did complete a substance abuse disorder assessment but “did not meet
medical necessity as she had declined [a] pattern of problematic substance
use.”

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 At the combined six- and 12-month review hearing, the juvenile court
found that although the Agency had made reasonable efforts and mother had
made adequate progress, it was not safe to return the children to her custody.
It ordered continued supervised visitation and the same reunification
services. The court also recommended that a therapist be part of the visits
and that the visits be “conducted separately between the children.”
E. 18-Month Review and Addendum Report
In its February 2026 status review report, the Agency recommended
that mother’s reunification services be terminated and that the matter be set
for a section 366.26 hearing as to Jasiah, Philecia, Nathaniel, Nicholas, and
Shantel. As for Chanel, the Agency also recommended that reunification
services be terminated and that the juvenile court continue the matter for a
six-month review for a permanent plan of “placement with a fit and willing
relative.” The report highlighted that a recent visit to mother’s home
confirmed that “conditions ha[d] not changed” as repairs were still needed
and “hazards remain[ed] unresolved.” Mother’s visits with the children had
also not improved. The Agency continued to provide transportation for all
the children, with weekly visits occurring on two different days in order to
separate the children.
Chanel and two of her siblings reported feeling unsafe during visits
with Shantel and Nicholas because they did not believe mother protected
them. The report noted that mother struggled to set limits or to intervene
during conflicts. Two of mother’s adult children began participating in the
visits at mother’s request and “often step[ped] in to provide structure,
support, and reinforcement of rules.” Mother continued to show “an ongoing
pattern of favoritism toward [Jasiah] while neglecting the emotional and

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developmental needs of her older children.” She, however, “consistently
denie[d] these behaviors.”
The report then summarized its concerns regarding minors’ behaviors
and their ongoing treatments. As for Chanel, the report stated that she
“continue[d] to be a resilient teen who [was] very charismatic, nurturing and
attentive to others.” She had “wraparound services in place to address
mental health and behavioral needs, which . . . support[ed] ongoing
permanency planning.”
Mother continued individual therapy but had still not adequately
addressed the safety concerns that led to minors’ removal. Mother also
completed parenting classes that were part of her “criminal case court
orders.” Family therapy had not started as Seneca was focused on stabilizing
“minors and their relationships.” Finally, mother submitted to random drug
testing for the first time in February 2026. She tested positive for opiates,
Benzodiazepine, and Oxycodone. Mother confirmed she did not have a
prescription for these drugs and had taken them for at least the past year “to
address gum pain and menstrual cramps.” The social worker advised mother
to seek a medical evaluation with her primary care physician regarding her
ongoing use of pain medication and recommended outpatient support
services.
The juvenile court continued the 18-month review hearing to April
2026 for a contested hearing. It ordered a minimum of one supervised visit
per month, giving the Agency discretion to increase or decrease visitation for
each child. Before the hearing, the Agency filed an addendum report, noting
that mother had stopped drug testing. According to the report, Chanel and
some of her siblings still reported feeling unsafe around Shantel and Nicholas
due to their “physically assaultive conduct . . . during visits.” In March,

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Jasiah informed the social worker that he witnessed violence between mother
and J.K. on two occasions in the home and that J.K. also physically harmed
Jasiah’s siblings.
The addendum report concluded that terminating reunification services
was appropriate due to ongoing and significant concerns regarding “mother’s
capacity to safely parent the minors without risk to their physical safety,
emotional well-being, and developmental needs.” Contributing factors
included mother’s “unresolved mental health issues, ongoing substance use,
and a demonstrated inability to consistently protect the minors from
exposure to harm, including violence.” The Agency further commented that
mother had over 18 months “to address the unsafe conditions in the home”
but had not done so and had declined the Agency’s offers of help.
F. Contested Hearing and Termination of Reunification Services
The juvenile court held a contested 18-month review hearing on April
22 and 27, 2026. Mother and social workers Nicole Lock and Maria Sanchez
testified. Lock was assigned to this case in March 2026 and had only worked
with the family for about six weeks. When she met with mother, mother
claimed that “the Agency ha[d] traumatized her children” and “ruined their
sibling relationships” and that “family therapy would have really helped.”
Mother did not identify any actions on her part that contributed to the
current situation. Lock also observed that mother had “extreme dry mouth,”
which suggested possible substance use. Lock testified that she did not
believe it was appropriate to return the children to mother at this time
because mother did not recognize why safety concerns were still present.
Sanchez testified next. She was assigned to this case in 2023 and had
worked with the family for about three years. When asked about the delay in
family therapy, she explained that this was a complex case involving “six

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children with different [and] specific behavioral, educational, and emotional
needs.” Before family therapy can begin, the clinician has to assess what the
child’s needs are and then “move on to the parent to see how appropriate it is
to include the parent in the therapeutic services.” Sanchez continued that “if
a parent is denying or does not believe that [he or she is] the root cause . . . or
has the insight,” it would “be a detriment to include the parent.” And in her
opinion, mother had not acknowledged or accepted the Agency’s safety
concerns, her role in those safety concerns, or how they impacted her
children.
With respect to her referral to Seneca, Sanchez testified that she
completed six individual packets, one for each child, in March or May 2025 to
request wraparound services for them. Once approved, Seneca assigned a
team that included at least two providers for each child in the late summer of
2025. Seneca was still working on “stabilizing the children within their own
therapeutic and behavioral needs” due to their “[n]eglect and trauma from
exposure to violence.” Sanchez had previously made another family therapy
referral to Foster Care Mental Health, but her subsequent referral to Seneca
superseded that earlier referral, as “both services [could not] exist at the
same time.” Sanchez did not believe the children’s clinicians were at a point
to recommend family therapy, as the children’s needs as well as their sibling
relationships were being prioritized.
With respect to therapeutic support during visits, Sanchez testified
that they did not occur but that she had made referrals. She explained that
after the referral process, it was “out of [the Agency’s] hands when those
services begin or how they are approved.” At times, however, the Agency had
three staff members present during visits for support. Sanchez did not
believe mother had developed insight into the effects of excessive physical

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discipline or domestic violence on her children, “how to effectively parent her
children as a group,” or “the causes of her children’s struggles.” (Boldface
omitted.) She accordingly concluded that mother was not currently capable
of safely parenting her children.
Mother testified that she had asked the Agency to provide family
therapy multiple times so she could “understand what [was] going on” and to
“talk as a family.” She also wanted to let her children know how she felt and
to apologize to them. She continued that the Agency never referred her to a
psychiatrist for a medication evaluation or to parent coaching. She attended
individual therapy weekly, which she found beneficial. With respect to issues
that occurred during visitation, mother explained, “[t]here’s a lot of kids that
want my attention. It’s very hard to give all my attention.” She
acknowledged that Nicholas had hit his siblings during visits and that he had
anger issues. Mother was currently unemployed and was in school to get her
high school diploma. As part of her diversion program in criminal court,
mother had to attend weekly therapy and complete a parenting class, which
she did. As for housing, mother testified that she just got a Section 8 housing
choice voucher and was in the process of moving out of her current home.
At the conclusion of the hearing, the juvenile court terminated
reunification services as to Chanel and set the matter for a permanent plan
of placement with a fit and willing relative. It also terminated reunification
services as to the other minors and set their matters for a section 366.26
hearing. The court found by clear and convincing evidence that reasonable
services were provided or offered to mother. It noted that although services
may not have been perfect, the Agency offered “an enormous panoply of
services” that included numerous providers assigned to address the complex
needs of each child. It further emphasized that there was still a number of

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safety concerns and that mother “showed absolutely no insight into her own
behaviors that may have impacted her children.” This included insight “on
the effects of domestic violence on the children, or the effects of excessive
discipline.” The court concluded that “family therapy [was] not the panacea
for what ails this family,” as mother “must develop insight into safety
concerns . . . in order for [her] to . . . even begin family therapy.”
Mother timely appealed the order as to Chanel.
II. DISCUSSION
A. Law and Standard of Review
“When a child has been removed from a parent’s custody, the [juvenile]
court ordinarily must order child welfare services designed to facilitate the
reunification of the family.” (Michael G. v. Superior Court (2023) 14 Cal.5th
609, 624.) Such services “ ‘enable [parents] to demonstrate parental fitness
and so regain custody of their dependent children.’ ” (Ibid.)
“Typically, when a child is removed from a parent, the child and parent
are entitled to 12 months of child welfare [(reunification)] services to
facilitate family reunification. These services may be extended to a
maximum of 18 months. (§ 361.5, subd. (a).) If, at the 12-month hearing,
[the agency] does not prove, by clear and convincing evidence, that it has
provided reasonable [family reunification] services to the parent, [those]
services must be extended to the end of the 18-month period. [(§§ 361.5,
subd. (a), 366.21, subd. (g)(1).)]” (Amanda H. v. Superior Court (2008) 166
Cal.App.4th 1340, 1345.) In some cases, reunification services “can even be
extended to 24 months if, among other findings, the court finds ‘reasonable
services have not been provided to the parent.’ ” (In re A.O. (2025)
111 Cal.App.5th 1048, 1060.)
We review the juvenile court’s findings for substantial evidence. (San

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Joaquin Human Services Agency v. Superior Court (2014) 227 Cal.App.4th
215, 223.) “In reviewing the reasonableness of the services provided, this
court must view the evidence in a light most favorable to the respondent. We
must indulge in all legitimate and reasonable inferences to uphold the
verdict. If there is substantial evidence supporting the judgment, our duty
ends and the judgment must not be disturbed.” (In re Misako R. (1991)
2 Cal.App.4th 538, 545.)
B. Analysis
Mother argues that the juvenile court erred in selecting a permanent
plan for Chanel because substantial evidence does not support its finding
that the Agency provided mother with reasonable reunification services.
Specifically, mother contends that she was never provided court-ordered
family therapy, recommended psychiatric services, or recommended
therapeutic support during her visits with minors. We are unpersuaded.
1. Family Therapy
Mother first contends that the Agency “fail[ed] to make any real effort
to assure that family therapy occurred” as it “simply provided a referral and
then sat back” for most of the reunification period. Mother further argues
that the Agency’s referral of Chanel and her siblings to Seneca “did
absolutely nothing to promote family therapy.” The record belies these
contentions.
Following an incident in April 2024 in which mother verbally
threatened Nicholas, the Agency initially referred mother to Family Mosaic
“to support [Nicholas].” Mother responded that she “[did] not want to be
bothered” and did not utilize the referral.7 In May 2025, the Agency made a

7 The Agency had also previously referred mother and Naeyah to family

therapy in July 2023, but mother was unwilling to attend.

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referral to Foster Care Mental Health for family therapy. Due to minors’
trauma and complex needs at the time, the Agency also submitted lengthy
intake packets on behalf of each minor (including Chanel) to obtain
wraparound services with Seneca around this same time. Once Seneca
approved minors for services in June, they could not simultaneously receive
services from Foster Care Mental Health. Seneca then assembled a team of
at least 12 providers who prioritized stabilizing minors (including Chanel)
“within their own therapeutic and behavioral needs.” Although Seneca’s
services included family therapy, minors’ providers did not recommend it yet
because they were focused on treating minors’ individual needs as well as
their sibling relationships. Thus, despite the lack of family therapy, the
services provided by the Agency were properly “tailored to fit the
circumstances of [this particular] family.” (In re Dino E. (1992) 6 Cal.App.4th
1768, 1777.)
Moreover, during the reunification period, mother’s therapist noted
that although mother consistently attended individual therapy, she failed to
adequately address the core safety concerns that led to minors’ removal. And
at the time of the 18-month review hearing, mother had still not gained
insight as to these safety concerns (including excessive physical discipline
and domestic violence), her role in them, or how they affected minors. Given
this, it would have been detrimental, according to the social worker, to
include mother in family therapy because minors’ trauma would not be heard
or addressed under those circumstances.
In any event, the Agency did make reasonable efforts to refer mother
and minors (including Chanel) to family therapy. Moreover, the delay in
establishing family therapy was not due to the Agency’s inaction, but rather
the need to prioritize and stabilize minors as a result of the trauma and

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neglect they experienced. (In re Julie M. (1999) 69 Cal.App.4th 41, 50 [“a
parent’s liberty interest in the care, custody and companionship of children
cannot be maintained at the expense of their well-being”].) Indeed, the
adequacy of the Agency’s “efforts to provide suitable services is judged
according to the circumstances of the particular case” (In re Taylor J. (2014)
223 Cal.App.4th 1446, 1451) and “not whether the services provided were the
best that might be provided in an ideal world” (In re Misako R., supra,
2 Cal.App.4th at p. 547).
In In re A.O., supra, 111 Cal.App.5th 1048, for example, the Court of
Appeal held that although the mother had not been able to visit with the
minor at the time of the six-month review hearing, the department of family
services had “made reasonable efforts to effect such visits in a way that would
not further harm [the minor].” (Id. at p. 1062.) The court therefore
concluded that reasonable reunification services were provided (id. at p.
1063), notwithstanding the importance of visitation as “ ‘an essential
component of any reunification plan’ ” (id. at p. 1062). The same is true here.
Indeed, ample evidence supports the juvenile court’s conclusion that
reasonable reunification services were provided, notwithstanding the
Agency’s failure to provide family therapy as ordered.
The two cases mother relies on are readily distinguishable. In In re
Taylor J., supra, 223 Cal.App.4th 1446, the mother failed to complete, as part
of her case plan, domestic violence victim counseling and individual therapy.
(Id. at p. 1451.) The Court of Appeal reversed the juvenile court’s reasonable
services finding because the department had simply handed mother a list
containing one domestic violence victim counseling agency near her home.
(Id. at p. 1452.) The department further did not verify the adequacy of the
counseling service the mother participated in for several months. (Ibid.)

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Here by contrast, the Agency itself made referrals to at least two different
family therapy providers, completed and presented intake packets so that
Chanel and her siblings could be approved for wraparound services, and kept
apprised of mother’s progress in individual therapy. Moreover, the service
providers, rather than the Agency, determined that family therapy was not
appropriate due to the mother’s and minors’ issues.
In the second case, In re Alvin R. (2003) 108 Cal.App.4th 962, family
therapy was “critical to reunification” because the minor refused to visit with
the father for four months, and “both the [juvenile] court and the social
worker recognized that visitation [was unlikely to] take place without
conjoint therapy.” (Id. at p. 972.) Conjoint therapy, in turn, “was not going to
be accomplished unless some effort were made to get [the minor] into
individual therapy.” (Id. at p. 973.) Despite this, the department’s only effort
to obtain individual therapy for the minor was “to make a referral to a
therapist who had no time available to see [the minor].” (Ibid.) It did not try
to find other therapists in the area or attempt to find transportation for the
minor to see an available therapist. (Ibid.) The Court of Appeal therefore
found that substantial evidence did not support the juvenile court’s
reasonable services finding. (Id. at p. 975.) Here, the Agency made multiple
referrals to family therapy and requested wraparound services for Chanel
and her siblings that were approved. And Chanel and her siblings were each
assigned at least two providers to treat their individual and complex needs,
and those providers decided against family therapy at the time. The Agency
even transported Chanel and her siblings to supervised visits with mother
and provided additional staff support during these visits. It had no legal
duty to do more.

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 2. Recommended Psychiatric Services
Mother next argues that the Agency did not make any effort to provide
her with psychiatric services, as recommended by mother’s psychological
evaluation. We disagree. The psychological evaluation concluded that
mother was “at a high risk for developing serious addiction issues” (italics
omitted) due to her family history and recommended “comprehensive
substance use services.” In response, the Agency requested that a substance
abuse assessment, random drug testing for the next six months, and a
psychiatric evaluation for medication assessment be added to mother’s case
plan. Mother completed a substance abuse disorder assessment in which she
self-reported that she did not have a pattern of problematic substance use.
As mother concedes, the juvenile court did not order psychiatric
services. Nonetheless, the Agency made good faith and reasonable efforts to
address concerns about mother’s potential substance use. It referred mother
to random drug testing and followed up with her about it, but mother was a
“no show” for all 12 appointments. When mother finally tested in February
2026 and disclosed that she had been taking unprescribed pain medication
for the past year, the Agency discussed its concerns with her and
recommended that she seek outpatient support services. It also advised that
mother seek a medical evaluation by her primary care provider regarding her
ongoing use of pain medication and management. Reasonable services were
therefore provided by the Agency, notwithstanding the lack of a psychiatric
evaluation.8 (In re Misako R., supra, 2 Cal.App.4th at p. 547 [services need

8 The circumstances here are easily distinguishable from those in In re

K.C. (2012) 212 Cal.App.4th 323. There, the Court of Appeal held that
reunification services were not reasonable because the department’s only
attempt to address the father’s mental health issues (the reason for his loss of
custody) was “to delegate the burden of finding and obtaining suitable

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not be perfect so long as they were reasonable under the circumstances].)
3. Therapeutic Support During Visits
Finally, mother contends that reunification services were inadequate
because the Agency failed to secure a therapist or parent coach for mother’s
visits with minors as ordered by the juvenile court. We do not agree.
First, the juvenile court recommended but did not order that a
therapist be present during visits. Mother seemingly acknowledges this in
her reply brief but nonetheless argues that it was “[f]or all intents and
purposes” an order because the court had commented at the 12-month review
hearing, “what I really need is a therapist to be at these visits.” We disagree.
In the colloquy that occurred before that comment, the court asked the
Agency whether a therapist could be present at visits. The Agency responded
that it was trying to “find loopholes and be creative here” because Senica did
not provide therapeutic support during supervised visitations. The court
eventually acknowledged that it could not order “clinical therapeutic
supervision.”
Second, contrary to mother’s contention that the Agency never
attempted to comply with the juvenile court’s recommendation, Sanchez
testified that she made referrals for the family to have therapeutic support
during visits. She continued, however, that it was “out of [the Agency’s]
hands when those services begin or how they are approved.” In the
meantime, the Agency continued to transport minors (including Chanel) to
the visitation site on a weekly basis, despite their many foster placement
changes. It also split the visits between two different dates to reduce sibling
violence and the number of children mother had to manage at a time.

services to [the] [f]ather himself.” (Id. at p. 330.)

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 Additionally, the Agency had up to three staff members present to
support mother’s visits with minors (including Chanel). And for special
events, CASAs were present as well. Two of mother’s adult children also
participated in the visits to help “provide structure, support, and
reinforcement of rules.” The social worker and other Agency staff also
provided feedback to mother regarding recommended changes to her behavior
during future visits, but mother did not accept the feedback and responded
that “she knew her children better.” We do not see what more the Agency
could have reasonably done under the circumstances to support mother
during visits.
On this record, we find that substantial evidence supports the juvenile
court’s finding by clear and convincing evidence that the Agency provided
reasonable reunification services.
III. DISPOSITION
The juvenile court’s order is affirmed.

CHOU, J.

WE CONCUR.

SIMONS, ACTING P. J.
BURNS, J.

A176348/ In re C.J. (SFHSA v. M.T.)

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