In re David W.
In February of 2011, the juvenile court declared five-year-old David W. a dependent pursuant to Welfare and Institutions Code section 300 and ordered the parents to share custody of the child.[1] Approximately one year later, David’s therapist reported that the parents’ ongoing, combative relationship had caused the child severe emotional distress, ultimately culminating in a psychiatric hospitalization. Based on this new information, the juvenile court ordered the child detained and the Los Angeles County Department of Children and Family Services (DCFS) filed a section 342 petition; following a contested adjudication and disposition hearing, the court sustained the petition and detained the child.
Father appeals the juvenile court’s jurisdictional and disposition orders, arguing that: (1) the court’s orders were not supported by substantial evidence; (2) the court exceeded its authorities by ordering DCFS to file a section 342 petition; and (3) the juvenile court violated the time limitations set forth in section 352, subdivision (b). We affirm the court’s orders, concluding that although the juvenile court violated section 352, father suffered no prejudice.
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