In re R.F.
Annotate this CaseThe father of R.F. appealed a post-disposition order and judgment dismissing the juvenile dependency case and entering exit orders and sole custody of R.F. to Mother, decreasing his supervised visitation, and requiring Father’s visitation to be supervised by a professional monitor at Father’s expense. R.F. and sibling L.F. were removed from his custody based on findings of drug abuse. Father contended on appeal that he did not receive notice and a meaningful opportunity to be heard before the juvenile court dismissed the proceedings and entered the exit orders. Father further argued that the errors were structural, requiring automatic reversal, and, if not structural, they constituted prejudicial reversible error. The Court of Appeal concluded there was no evidence in the record that Father received proper notice or an opportunity to be heard before the juvenile court terminated dependency jurisdiction and imposed the exit orders. In addition, the visitation order was ambiguous as to whether the court ordered visitation a minimum of once a week or every other week. The Court held these errors constituted prejudicial error requiring reversal of the order terminating dependency jurisdiction, the exit orders, and the judgment entered on January 15, 2021.
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