In re Leon E.
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Leon, age 15, was declared a ward of the juvenile court after admitting to six felonies, including sex crimes. He was placed at a residential treatment facility. Leon turned 18 years old and was returned to juvenile hall after a probation violation. He was later committed to the Youthful Offender Treatment Program. Leon then transitioned into juvenile court as a nonminor dependent through the extended foster care program and entered into a transitional independent living plan, which required him to attend an education program, or be employed. In 2019, Leon moved into a transitional housing placement plus foster care (THP+FC) facility. The juvenile court later terminated Leon’s nonminor dependency, finding that he was not participating in AB12 in good faith and was not residing in his THP+FC placement. California's Fostering Connections to Success Act (AB12), allows nonminor dependents to remain under juvenile court dependency jurisdiction and receive financial assistance until age 21 if they comply with statutory requirements. Leon is now 21 years old.
The court of appeal concluded the appeal is not moot because a reversal could still afford Leon effective relief in the form of certain documentation. While the juvenile court did not abuse its discretion in finding that Leon failed to meet AB12 eligibility requirements, the order terminating dependency jurisdiction must be remanded to ensure compliance with the procedural requirements of section 391(a)–(c), (h) in the form of the provision of certain information, documents, and services.
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