In re D.W.
In this second of two companion cases,[1]mother Iris P. and Patrick P.the stepfather of minor D.W. and the father of minors K.P. and J.P.each challenge a juvenile court order placing the minors out of their home. Iris and Patrick each appeal from the order entered after the six-month review hearing in this juvenile dependency matter. In the companion appeal, we concluded that the underlying findings of jurisdiction over D.W., K.P. and J.P. were made in violation of Iris and Patricks due process rights. (In re D.W. (Apr. 9, 2008, A115960) [nonpub. opn.].)
The purpose of a review hearing is to review the status of a dependent child. (See Welf. & Inst. Code, 366.21.) A child is not a dependent of the juvenile court unless that court has first made proper jurisdictional findings. (See id., 300.) As the six-month order before us in this appeal is based on jurisdictional findings that Court overturned in the companion appeal, the order after the six-month review hearing must likewise be overturned.[
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