In re V.L.
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The Court of Appeal affirmed the juvenile court's dispositional order removing son and daughter from father's custody. The court heeded the holding of Conservatorship of O.B. (2020) 9 Cal.5th 989, 995–996, establishing that when a statute requires a fact to be found by clear and convincing evidence, and when there is a substantial evidence challenge, the reviewing court must determine whether the record contains substantial evidence from which a reasonable trier of fact could find the existence of that fact to be highly probable.
In this case, the court held that a reasonable trier of fact could have found it highly probable that placement of the minors with father would pose a substantial risk of them being harmed by exposure to future domestic violence, and that there were no reasonable means to protect the minors without removal from father's physical custody. The court rejected father's arguments to the contrary and his argument that the juvenile court's failure to state the facts it relied upon is reversible error. Because the last incident of domestic violence involving father was so dangerous and troubling, it is not reasonably probable that the juvenile court would have reached a different conclusion if it stated the facts it relied upon.
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