In re M.S.
Annotate this CaseT.S., mother of M.S., appealed an order at M.S.'s jurisdiction and disposition hearing denying Mother reunification services based on the juvenile court's finding that Mother's whereabouts were unknown pursuant to Welfare & Institutions Code section 361.5(b)(1), and setting a section 366.26 permanency planning hearing. Mother also appealed the court's subsequent order at the section 366.26 hearing terminating her parental rights. On appeal, Mother contended: (1) there was insufficient evidence to support the court's finding at the jurisdiction and disposition hearing that her whereabouts were unknown within the meaning of section 361.5(b)(1), and, accordingly, it erred in denying her reunification services; and (2) the court also erred at the jurisdiction and disposition hearing by setting a section 366.26 hearing after denying reunification services to her under section 361.5(b)(1), and by subsequently terminating her parental rights at the section 366.26 hearing. The Court of Appeal agreed with Mother's contentions, and reversed the orders and remanded the matter to the juvenile court with directions that it, inter alia, order that Mother be provided with a minimum of six months of reunification services.
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