Michael G. v. Superior Court of Orange County
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After determining that Father’s delusions and paranoia put A.G.(age 14) at risk of serious harm, the juvenile court assumed jurisdiction, ordered that A.G. be removed from Father’s custody, and ordered reunification services and a psychological evaluation. At the six-month hearing, the Agency reported that Father had received his case plan several months earlier but had not signed the plan nor engaged in recommended services. Father also resisted psychological evaluation. At the 12-month hearing, the Agency reported that Father had made moderate progress. The court granted an extension, finding that the Agency had provided reasonable services. At the 18-month hearing, the Agency reported that returning A.G. to Father’s custody still presented a substantial risk of detriment to her well-being and recommended a permanency planning hearing. The court found that the Agency had not provided reasonable services between the 12- and 18-month hearings but declined to exercise its discretion to continue the case, noting Father’s uneven progress.
The California Supreme Court affirmed. Reasonable reunification services must be offered to qualifying parents for a minimum of six or 12 months, depending on the child’s age, and generally may be extended for up to 18 months. The court was not automatically required to grant a further extension based on its finding that reasonable services were not provided during the 12- to 18-month extension. Once a child has been out of the parent’s custody for 18 months, the law ordinarily requires the court to proceed to set a hearing to determine a permanent plan.
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