In re Aaron S.
Annotate this CaseAaron S. was adjudged a dependent minor when he was 16 years old and became a non-minor dependent when he turned 18,Welf. & Inst. Code, 11400(v). The juvenile court terminated dependency jurisdiction shortly before Aaron turned 19, finding that by not enrolling in school or having a job, Aaron failed to participate in his Transitional Independent Living Case Plan. Aaron claimed that the Santa Clara County Department of Family and Children’s Services did not provide him a 90-day transition plan. The court of appeal affirmed. Even assuming the issue was not forfeited, termination without proof of a 90-day transition plan was harmless here because the Department separately provided information to Aaron regarding each of the categories that would have been included in the plan. For housing, employment, educational and continuing support services information, the emancipation letter that was mailed to Aaron before the termination hearing referred him to his Independent Living Program case manager and provided contact information for Transitional Housing Program providers. That letter also informed Aaron he was eligible for health benefits through Medi-Cal, and the section 391 report indicated the Department mailed Aaron a copy of the advanced health care directive form.
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