Filed 11/2/26 K.L. v. Super Ct. CA4/2
NOT TO BE PUBLISHED IN OFFICIAL REPORTS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 This opinion has not been certified for publication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
FOURTH APPELLATE DISTRICT
DIVISION TWO
K.L.,
Petitioner, E088981
v. (Super.Ct.No. J302935)
THE SUPERIOR COURT OF OPINION
SAN BERNARDINO COUNTY,
Respondent;
SAN BERNARDINO COUNTY
CHILDREN AND FAMILY SERVICES,
Real Party in Interest.
ORIGINAL PROCEEDINGS; petition for extraordinary writ. Michelle Lauron,
Judge. Petition denied.
Scott Bowen, and Juvenile Court Attorneys of San Bernardino, LLP, for
Petitioner.
Laura Feingold, County Counsel, and David R. Guardado, Deputy County
Counsel, for Respondent.
1
K.L. (Mother) seeks an extraordinary writ (see Cal. Rules of Court, rule 8.452) to
set aside the juvenile court’s order terminating her reunification services with her infant
son, B.B. (Minor), and setting a permanent plan selection and implementation hearing
under Welfare and Institutions Code section 366.26 (.26 hearing). (All further statutory
references are to this code.) Mother challenges the sufficiency of the evidence to support
the juvenile court’s findings that returning Minor to her custody would be detrimental
and that San Bernardino County Children and Family Services (CFS or the Department)
provided reasonable services. Mother also contends the court abused its discretion in
reducing her visitation pending the .26 hearing. As we explain, Mother’s contentions are
without merit, and we therefore deny Mother’s writ petition.
FACTUAL AND PROCEDURAL BACKGROUND
In November 2024, Mother and a maternal aunt brought Minor to the emergency
room with what medical staff described as a “profound” hematoma and abrasions on the
side of his head. Mother had severe bruising to both of her eyes. She and Minor suffered
their injuries two days earlier. Mother said she had been in an argument with the child’s
father, G.B. (Father), when she tripped with Minor in her arms and fell to the ground,
losing consciousness. Mother claimed she reported the incident to the sheriff’s
department the day it occurred, but no report was found. Mother departed the hospital
against medical advice immediately after a doctor examined Minor, before x-rays or a
CT scan could be performed. Minor was three months old at the time.
2
Departmental inquiry uncovered an active warrant for Mother for driving under
the influence of drugs. Her criminal history included another warrant for battery, and
Father had active warrants for attempted murder, domestic violence, and criminal threats.
Family members reported concern for Minor’s safety based on domestic violence
in the home, including another recent incident in which Mother was injured. Mother
admitted in text messages to a friend that she had a restraining order against Father and
she told the friend that if she were found with Father, “[Minor] will get taken.” Mother
also told her friend that Father kicked Minor in the head while she held him, and he
kicked her in the ribs, knocked her down, and tried to stab her. Mother thought the
relationship could recover if Father “went to therapy.” Mother refused housing with
relatives conditioned on leaving Father.
Mother was located by deputies at the paternal grandparents’ home the same day
she had been to the emergency room with Minor. Mother told the deputies that, two days
earlier, she tripped on a toy while running from Father when he forced his way into the
home. Scans at the hospital disclosed Minor suffered a skull fracture; Minor was
admitted to the pediatric intensive care unit. The skull fracture was underneath the large
hematoma on Minor’s head. Elevated liver enzymes indicated possible abdominal
trauma. Minor had bruising to his left knee, left shoulder, and left ear, and torn
connective tissue in his mouth. Minor was placed in a full body cast to avoid injuring
himself when moving his body.
3
CFS obtained a detention warrant and filed a dependency petition seeking the
juvenile court’s protection for Minor based on physical abuse, domestic violence, and
both parents’ unresolved substance abuse. (§ 366, subds. (a), (b), (e).) The petition
alleged Mother’s failure to rehabilitate from substance abuse “place[s] [Minor] at risk for
abuse and neglect” by “impair[ing] her ability to provide appropriate care and supervision
for [him].”
CFS continued its investigation in advance of the jurisdiction and disposition
hearing. Mother said in an interview that Minor received his injuries from Father
“stomping and kicking” her while Mother was on the ground. Father denied the abuse,
claiming Minor was injured in a fall while in Mother’s care.
Mother was 23 years old when Minor was detained. She had been smoking
marijuana for 10 years, beginning at age 13. She told the social worker in
December 2024 that, after Minor was detained, she enrolled in a treatment program. She
reported to the social worker that, after joining the program, she had “been clean for three
weeks.” The next month, a January 2025 progress report from Mother’s substance abuse
program indicated she had tested positive for marijuana use seven times since entering
the program and that she did not have a clean test until early January 2025. Her next
three tests in January 2025 were negative. Mother’s reunification case plan included
outpatient substance abuse treatment, domestic violence classes, parenting education,
individual therapy, and random drug testing.
4
Medical reports submitted before the jurisdiction hearing summarized Minor’s
injuries as acute closed head trauma that included a displaced skull fracture, acute
abdominal trauma indicative of “abusive squeezing,” oral trauma, and injuries to his left
upper and lower extremities. The court noted that Minor’s injuries included two broken
ribs and torn frenulum connective tissue in his mouth, “which can be caused by shoving
something in[], such as a baby bottle.” The juvenile court found the allegations of the
petition true, including dependency jurisdiction based on Mother’s unresolved history of
substance abuse. The court ordered reunification services for Mother and denied them
for Father given the severity of the physical abuse. (§ 361.5, subds. (b)(5) & (6).)
In August 2025, CFS’s report for the six-month review hearing recommended that
Mother “needs to complete the remainder of her services to address her history of
substance abuse and domestic violence to demonstrate she can provide adequate care for
[Minor].” The report observed that due to Minor’s infancy, Mother’s reunification period
would typically be limited to another six months.
Mother missed four random drug tests for the Department in the review period
before the six-month review hearing. In her case plan, she agreed that “[a]ny missed or
diluted test will be considered a positive test.” Mother had negative drug tests through
her substance abuse program on or near the four dates she missed for random Department
testing. Mother had negative tests on 10 other dates between late February 2025 and the
review hearing in late August 2025. Mother tested positive for amphetamines on April 4,
2025.
5
Mother requested, and her social worker provided, a gas card for Mother to attend
the six-month review hearing on August 25, 2025. Among other findings, the juvenile
court found at the hearing that the Department had provided reasonable services through
that date. The court continued reunification services for Mother for another six months.
For the 12-month review hearing, the Department initially recommended
extending Mother’s reunification services for another six months. Mother had completed
four of 12 domestic violence classes and four of eight individual therapy sessions, with
reports from both programs showing progress. Mother had transitioned in her substance
abuse program from outpatient services to recovery services, and was reported to be
“doing well,” including by engaging with her peers.
During the review period, Mother tested negative for drugs or alcohol 13 times
through her substance abuse program. In random Departmental testing, Mother tested
negative seven times, but she missed 10 tests, including in late December 2025 before the
early January 2026 review hearing. Mother’s cue color on call-in for random testing was
brown; Mother said she believed her testing color was red and she claimed she called the
testing service three times to determine if her color had changed from red.
Mother reported that her weekly visits with Minor had been “going well.” Mother
generally missed the first and last half hour of each visit. Her visitation order provided
for at least three hours per week with Minor, and the foster parent who monitored visits
made Minor available for a total of four hours: two hours twice a week at CFS’s Yucca
Valley office.
6
The juvenile court continued the 12-month review hearing scheduled for
January 9, 2026, when the Department changed its recommendation from continuing
reunification services to terminating them, based on the latest missed drug test in late
December 2025 and Mother’s still incomplete case plan. Before continuing the hearing
on January 9, the court at the hearing ordered Mother to test that day. At the new hearing
date on January 23, 2026, the court again continued the hearing to late February 2026.
Mother tested negative on January 9, January 12, and January 23, with test results
pending from January 29, as of the February 27, 2026 hearing date.
Mother falsified her test result for her January 29 testing date. She altered the date
of a previous negative test and resubmitted it as a new test result. Neither the court nor
the Department were aware of the false test result at the rescheduled 12-month review.
At the hearing, the Department reverted to its original recommendation that the court
continue Mother’s reunification services for another review period. In addition to three
January 2026 negative test results (not including the later falsified January 29th test),
Mother represented that she had three domestic violence prevention sessions left to
attend, she would soon complete individual counseling, and she had transitioned to after-
care in her substance abuse program. The court adopted CFS’s recommendation,
extending Mother’s reunification period to the 18-month mark. The court expanded
Mother’s visitation to three hours twice a week and also found CFS provided reasonable
reunification services through the 12-month review period.
7
Mother completed most of the components of her case plan by the 18-month
review hearing, except substance abuse testing. She continued to miss testing dates in the
final review period—as many as seven, with only one explained. She failed to test on
January 29, February 5, February 26, March 3, April 2, June 5, and July 2. Mother told
the social worker regarding the missed April 2 test that she was denied testing when she
arrived, but Mother refused the worker’s request for details, including the test location.
Mother said she had a negative test result for the missing March 3 date, which the worker
later verified.
Mother admitted she falsified the January 29 negative test result, but only after the
social worker checked Mother’s submitted result against the test site’s receipt, which
confirmed Mother missed her test that day. The social worker also discovered Mother
lied about not being able to test on the missed February 5 date because she was
hospitalized. Mother’s last test before the July 7 contested 18-month review hearing was
a negative test on May 27, 2026. Mother continued to miss tests as the 18-month review
approached: she failed to appear for tests on June 5 and on July 2, just before the hearing
date.
The social worker’s primary concern in recommending termination of
reunification services was Mother’s poor record of missing random drug tests. The
continual failure to test meant Mother “has not removed the threat of substance abuse”;
moreover, Mother had “exhausted the statutory time frame [for] reunification.”
8
In addition to the missed tests, the social worker’s report noted Mother’s pattern of
cancelling visits with Minor or leaving them early, including regularly by an hour or
more, which Mother minimized as “10-15 minutes early.” Mother’s explanations
included telling the visitation monitor she could not make the February 5 visit because
she was traveling, while she told the social worker she was at the hospital, which was
untrue.
Mother testified at the contested hearing. She testified that she falsified the
January 29 test result “out of fear” and that she missed the February 5 test date not
because she was in the hospital or traveling, as she had previously said, but because she
was working and “had to make money.” She testified she confused the dates she was
hospitalized: it had been December 5, not February 5. Mother testified she missed her
February 26 test because she hung up the phone too quickly, before hearing that her
assigned color for random testing was called. She also missed tests because she did not
know her color for the randomized call-in tests.
Mother testified she sometimes could not test in her hometown of Yucca Valley
and would have to go to San Bernardino, “hours” away, but she was hindered by lack of
transportation. She said she communicated the problem to CFS in March or April of
2026, but “nothing” was done to assist her. She acknowledged she received bus passes
before she obtained a car in early April. She also said she “got, like, two gas cards.” She
explained her recent missed visitation was due to her work schedule or medical issues.
9
The social worker testified Mother was provided with transportation assistance
that included bus passes and, on the few times she requested them, gas cards. When
Mother’s counsel asked the social worker if she were aware Mother had “transportation
issues” affecting her visitation, the worker responded that Mother made no such
complaints. To the contrary, the worker expressed concern that Mother provided
inconsistent reasons to CFS and to Minor’s caretaker regarding leaving visits early,
sometimes telling one “she’s going to work” while blaming in statements to the other,
variously, the visitation “schedule, location, being bored, . . . just different conflicting
statements.”
The social worker testified the Department’s principal concern was Mother’s
missed tests, inconsistent testing, and the falsification of her testing record and reasons
why she missed tests. These factors raised concerns about Mother’s truthfulness and her
drug sobriety, and, in turn, Minor’s safety. The worker noted, for instance, that “it looks
like Mother chooses to go [to testing on dates] when she knows quite well her color was
not called,” consistent with hiding drug use. The worker acknowledged that a few dates
initially listed as no-shows turned out subsequently to have negative test results or
Mother had a valid reason for not taking a test, such as testing positive for Covid. On
other dates Mother claimed to have tested, she did not furnish promised documentation or
tell the social worker where she tested.
In an updated report provided to the court between hearing dates, social workers
summarized that they confirmed with Mother’s Yucca Valley testing site that Mother
10
missed 21 tests at the site, dating back to the beginning of the case in November 2024.
She had 14 negative tests there. She tested positive for amphetamines on April 4, 2025.
The court found by a preponderance of the evidence that returning Minor to
Mother’s custody would create substantial detriment to Minor. The court noted “how
[Mother] performed on her program is obviously relevant to that consideration, whether
there’s going to be a risk to the child.” The court commended Mother for “progress in
several aspects of her program.” The court found Mother’s missed tests “very
concerning,” noting the standard warning to her and parents in dependency proceedings
that “a missed test is considered a positive test.” While the court observed “it would be
different if it was a few missed tests,” Mother’s 21 missed tests at her Yucca Valley
location, out of approximately 35 testing opportunities there, meant that she “chose not to
test for one reason or another” approximately “two-thirds of the time.” The court
analogized that if Mother had missed that much of her domestic violence program or her
individual counseling, it would show detriment by indicating “she didn’t benefit from
that part of the program.” “In fact,” the court observed, “those services would have been
terminated for lack of participation.”
The court found the missed tests “telling” because they represented multiple
opportunities “to succeed or to fail,” particularly because the court, in extending services
to 18 months, had overruled CFS’s concern about “all of the missed tests,” as discussed
“abundantly” at the last review. Mother to that point had missed 14 random tests at the
Yucca Valley facility and then missed “seven more times.” The court noted that the
11
concern in requiring the tests was “can [Mother] maintain sobriety,” to “make sure that
the child is going to be safe and well-cared for.” The missed tests indicated to the court
“lack of . . . awareness” of the importance of “every aspect of this case plan,” including
“how important it is for a child to have a safe environment, including one where the
parent will comply with what they have to do. It shows a lot to this Court.”
The court added as “very concerning” that Mother “has been untruthful in many
ways.” The court found the forged test result “extremely problematic” because “you go
from a lie [about whether or why a test was missed], which was already bad,” to “outright
forgery” perpetrated “on CFS” and the court. While Mother said she did it “out of fear,”
the court noted Mother continued to miss tests in the new and final review period, lending
support to the inference that Mother actually feared “maybe that was [going to be] a
positive test”—to be concealed by skipping it and fabricating evidence.
The court noted other grounds on which Mother lacked credibility. These
included saying that she had “transportation issues” requiring her “to leave [visits]
20 minutes earlier in order to get a bus,” which the court ordinarily would be “very
sympathetic to that.” But the court found Mother “actually left the visits 45 minute[s
early], came an hour late, left one hour early.” The court concluded Mother’s visits
“were inconsistent at best.” The court also questioned Mother’s truthfulness regarding
difficulties in testing or in transportation to visits. The court observed that Mother
“indicated that she was not currently working, so I don’t know . . . why there were missed
tests and missed visits in the last few months . . . .” Additionally, Mother never
12
complained of transportation problems for her parenting classes or “things of that
nature,” but only as to testing in her hearing testimony. The court noted further that after
18 months of reunification services, Mother’s visits remained supervised, making
Minor’s return to Mother’s custody unlikely even if services could be extended.
The juvenile court found Minor could not be safely returned to Mother’s custody
at the 18-month review and that the Department had provided reasonable reunification
services. The court terminated Mother’s court-ordered reunification services and set a
.26 hearing for December 2026. The court reduced Mother’s visitation with Minor in
anticipation of the .26 hearing, but doubled the Department’s recommendation of one
visit a month for two hours, to two hours twice a month. Also over the Department’s
objection, the court authorized a bonding study for Mother and Minor.
DISCUSSION
Mother contends the juvenile court erred: (1) in finding a risk of detriment if
Minor were returned to her physical custody at the 18-month review hearing, (2) in
finding the Department provided reasonable reunification services and in not extending
services, and (3) in reducing her visitation before the pending .26 hearing. We address
each of these contentions in turn.
A. Risk of Detriment
“The Legislature has determined the juvenile court may generally offer family
reunification services for a maximum period of 18 months. [Citations.] At the 18-month
permanency review hearing the juvenile court must order a child returned to a parent’s
13
custody unless it finds, by a preponderance of the evidence, that return of the child will
create a substantial risk of detriment to the child’s safety, protection or physical or
emotional well-being.” (Georgeanne G. v. Superior Court (2020) 53 Cal.App.5th 856,
864, fn. omitted (Georgeanne G.); see § 366.22, subd. (a)(1).) “[T]he risk of detriment
must be substantial, such that returning a child to parental custody represents some
danger to the child’s physical or emotional well-being.” (In re Yvonne W. (2008)
165 Cal.App.4th 1394, 1400, italics omitted.)
“We review the juvenile court’s finding of detriment for substantial evidence.”
(Georgeanne G., supra, 53 Cal.App.5th 856, 864.) “ ‘ “In making this determination, we
draw all reasonable inferences from the evidence to support the findings and orders of the
dependency court; we review the record in the light most favorable to the court’s
determinations; and we note that issues of fact and credibility are the province of the trial
court.” [Citation.] “We do not reweigh the evidence or exercise independent judgment,
but merely determine if there are sufficient facts to support the findings of the trial
court.” ’ ” (In re I.J. (2013) 56 Cal.4th 766, 773.)
Mother misplaces reliance on Jennifer A. v. Superior Court (2004)
117 Cal.App.4th 1322 (Jennifer A.) to argue that her missed tests and credibility concerns
did not establish risk of harm to Minor. Mother says of Jennifer A. that the reviewing
court “granted writ relief because technical noncompliance with testing did not, in
context, constitute substantial evidence of detriment.”
14
Context, however, makes all the difference. In Jennifer A., the children were
removed from the mother’s custody because she left them alone on one occasion when
she had to go to work; the father had not yet arrived home by the time she had to leave
because his car broke down. (Jennifer A., supra, 117 Cal.App.4th at p. 1343-1344.) The
mother missed nine of 95 twice-weekly drug testing obligations, was unable to void once,
had diluted specimens five times (after being told to drink “a lot” of fluids to be able to
void for the tests), and she tested positive for marijuana once, with no prior substance
abuse history. (Id. at pp. 1330, 1333-1334, 1343.) Mother admitted and regretted her
marijuana use the time she tested positive. (Id. at p. 1339.) The reviewing court found
no evidence linking the mother’s single use of marijuana to her parenting skills or
judgment where she was cooperative with the social worker and her case plan, had
progressed to a trial period of custody with her children with no noted concerns, and
otherwise displayed appropriate parenting and good judgment. (Id. at pp. 1346-1347.)
Mother’s conduct here stands in marked contrast where she missed two-thirds of
her random tests, falsified evidence and demonstrably lied about missed tests, was not
credible about missing or substantially curtailed visits, and never progressed to
unmonitored visitation or home visits. The juvenile court reasonably could regard
Mother’s credibility and character as paramount concerns to ensure Minor’s safety, given
the grievous harm he suffered from her prior lapses in judgment. The court had also
extended reunification services at the 12-month review hearing so that Mother could
demonstrate reliable compliance with random testing, but she did not do so.
15
Mother argues her missed tests did not “establish what the result of an
unperformed laboratory test would have been,” but the pattern, timing, and pervasiveness
of Mother’s missed tests supported an inference she was hiding drug use. Mother would
not meet with the social worker at home, only over the telephone, she had a pervasive,
10-year history of marijuana use dating back to when she was 13 years old, her arrest
warrant history included driving under the influence of drugs, she tested positive for
amphetamines, and there was evidence she attempted with a prior caretaker—a relative—
to purchase cocaine. Mother knew a missed test constituted a positive test under her case
plan, but skipped them anyway, supporting the conclusion those tests would have been
positive had she taken them.
On appeal, we “must be ever mindful of the fact that it is the exclusive province of
the trier of fact to determine the credibility of a witness and the truth or falsity of the facts
upon which a determination depends.” (In re Ryan N. (2001) 92 Cal.App.4th 1359,
1371.) The juvenile court is “the sole judge of the credibility of witnesses; we are not.”
(Id. at pp. 1371-1372.)
Mother argues she substantially completed her case plan, but “simply complying
with the reunification plan by attending the required therapy sessions and visiting the
children is to be considered by the court; but it is not determinative. The court must also
consider the parents’ progress and their capacity to meet the objectives of the plan;
otherwise the reasons for removing the children out-of-home will not have been
ameliorated.” (In re Dustin R. (1997) 54 Cal.App.4th 1131, 1143.) The question remains
16
“whether the counseling, therapy or parenting classes are doing any good.” (Blanca P. v.
Superior Court (1996) 45 Cal.App.4th 1738, 1748.) Mother continually demonstrated
she could not be counted on to comply with an essential component of her case plan,
despite reminders from the Department and extensions by the juvenile court. Nor did she
consistently visit Minor, establish she was free of her lengthy history of substance abuse,
or provide any evidence she could safely and protectively parent him if he were returned
home. Substantial evidence supports the juvenile court’s detriment finding.
B. Reasonable Services
At the 18-month review hearing, “[t]he court shall determine by clear and
convincing evidence whether reasonable services have been offered or provided to the
parent or legal guardian.” (§ 366.22, subd. (a)(3).) “The court shall not order that a
hearing pursuant to Section 366.26 be held unless there is clear and convincing evidence
that reasonable services have been provided or offered to the parent or legal guardian.”
(§ 366.22, subd. (b)(3)(C)(iii).)
“The . . . reasonableness of the [Department’s] efforts are judged according to the
circumstances of each case.” (Robin V. v. Superior Court (1995) 33 Cal.App.4th 1158,
1164.) “The standard is not whether the services provided were the best that might be
provided in an ideal world, but whether the services were reasonable under the
circumstances.” (In re Misako R. (1991) 2 Cal.App.4th 538, 547 (Misako R.).)
We review the juvenile court’s findings for substantial evidence. (In re A.O.
(2025) 111 Cal.App.5th 1048, 1061-1062.) “In reviewing the reasonableness of the
17
services provided, [an appellate] 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.” (Misako R., supra, 2 Cal.App.4th at p. 545.) Since
Mother bears the burden of demonstrating error on appeal, she must show that the
juvenile court’s reasonable services finding is not supported by substantial evidence.
(Angela S. v. Superior Court (1995) 36 Cal.App.4th 758, 762.)
Mother contends the Department “did not adequately address the known
transportation and testing barriers.” (Boldface and capitalization removed.) Mother
relies on her testimony that she informed the Department in “March or April” about
testing difficulty at her Yucca Valley site, requiring her to go to San Bernardino. Mother
also says she told the social worker the visitation schedule did not work for her, but no
change was made because of the monitor’s schedule. Mother claims the juvenile court
should have extended her reunification services to 24 months under section 366.22,
subdivision (b)(2)(A), which opens reunification services for another six months when
reasonable services have not been provided.
These contentions are answered by Mother’s poor credibility. As to visits, the
social worker testified Mother’s excuses for missed or shortened visits were contradictory
and did not involve transportation, and the juvenile court found Mother’s scheduling
claim unpersuasive. In particular, the court noted that Mother “was not currently
working, so I don’t know . . . why there were missed tests and missed visits in the last
18
few months.” Additionally, the court found generally that Mother’s irregular and
“spotty” visits weren’t satisfactorily explained, indicating the court rejected Mother’s
claim of a scheduling conflict and her other excuses. As to testing, we similarly must
presume the court credited the social worker’s testimony that she addressed the
transportation issue Mother raised, which only involved gas cards, not a lack of nearby
random testing. Moreover, we note that the 21 missed tests the juvenile court faulted
Mother for were at her hometown Yucca Valley testing site, not elsewhere, as reflected in
the social workers’ supplemental report. Consequently, Mother does not meet her burden
to establish the juvenile court erred in finding the Department’s visitation and testing
services were reasonable.
C. Reduced Visitation
Section 366.21, subdivision (h), requires the juvenile court to continue visitation
pending a .26 permanent plan selection and implementation hearing, unless it finds that
visitation would be detrimental to the child. The statute does not require maintaining the
frequency of visitation provided in the reunification period. (§ 366.21, subd. (h).) Once
reunification services are terminated, the focus shifts to providing dependent children
with stable, permanent homes. (Maricela C. v. Superior Court (1998) 66 Cal.App.4th
1138, 1145.) Parental interests, including in visitation, are “no longer ‘paramount,’ ” but
instead wane in favor of permanency and stability. (In re D.B. (2013) 217 Cal.App.4th
1080, 1090.)
19
Mother argues that the Department’s rationale for reducing visitation because
reunification services ended and the focus shifted to permanency “falls with the
termination order.” Mother states: “If this Court directs a new review hearing and the
juvenile court orders additional services, the visitation reduction should likewise be
vacated . . . .” This conditional argument fails because no new review hearing is
required, given that Mother’s challenges to the juvenile court’s detriment and reasonable
services findings are without merit. Moreover, with the shift in focus to planning for
permanency, we find no abuse of discretion in the juvenile court’s partial reduction in
visitation.
DISPOSITION
Mother’s petition for an extraordinary writ is denied.
NOT TO BE PUBLISHED IN OFFICIAL REPORTS
LEE
J.
We concur:
McKINSTER
Acting P. J.
RAPHAEL
J.
20
