In re Abram L.

INTRODUCTION

Appellant Abel L. (father) appeals the juvenile court‟s dispositional order granting physical custody of his sons, Abram L. and Jacob L., to respondent Los Angeles County Department of Children and Family Services (the Department) for suitable placement. The court removed the children from their biological mother, Juanita R. (mother), after she allegedly threatened them with physical harm. Because father was a noncustodial parent, the juvenile court was required to adjudicate his request for physical custody of the children pursuant to Welfare and Institutions Code section 361.2.1 Under the statute, father was entitled to physical custody of the children unless the juvenile court found that placement with father would be detrimental to the safety, protection, or physical or emotional well-being of the children. (§ 361.2, subd. (a).) The juvenile court, however, did not make an express finding of detriment as the statute requires (§ 361.2, subd. (c)), and it is unclear from the record whether the court considered the requirements of the statute before denying father‟s request for custody of his children. We thus reverse the order and remand the case for further…