In re D.H.
Annotate this CaseJason H. (father) appealed the juvenile court’s determination to deny him reunification services with the minors, now 16-year-old D.H. and seven-year-old T.H. The trial court found two reunification bypass provisions applied: (1) father had previously had reunification services and his parental rights terminated to the minors’ half siblings and father had not made reasonable efforts to treat the problems that led to the removal of the half siblings; and (2) father was incarcerated and the provision of services would be detrimental to the children. Father argued these bypass provisions did not apply as he had made reasonable efforts to treat the problems that led to the removal of the half siblings and reunification services were in the minors’ best interest; and, it would not be detrimental to the minors for him to be provided reunification services. Upon review, the Court of Appeal agreed with father that there was not sufficient evidence to support the finding that he had not made reasonable efforts to treat the problems that led to the removal of the half siblings, because the record revealed that the problems that led to the removal of the half siblings (unsafe and unhealthy conditions) were different from those presented in this case (alcohol abuse, anger management problems and domestic violence); nor did the record establish any connection between the two sets of problems or even that father received services in the prior case for the problems manifest in the present case. However, the Court found sufficient evidence to support the finding that father was incarcerated and it would be detrimental to the minors to provide services. Accordingly, the Court affirmed the juvenile court.
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