B.D.

B.D. v. Super. Ct.

Good Law
Court of Appeal of CaliforniaApril 30, 2025A172485California10,260 words

Opinion

Opinion

Fujisaki, J.

Filed 4/30/

CERTIFIED FOR PUBLICATION

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIRST APPELLATE DISTRICT

DIVISION THREE

B.D.,

Petitioner, v.

THE SUPERIOR COURT OF A172485

CONTRA COSTA COUNTY,

(Contra Costa County Respondent; Super. Ct. Nos. J24-00072, J24-

CONTRA COSTA COUNTY 00073)

CHILDREN AND FAMILY

SERVICES BUREAU,

Real Party in Interest.

B.D. (Mother) seeks extraordinary relief from a juvenile court order at the six-month review hearing that terminated family reunification services and set a permanency planning hearing under Welfare and Institutions Code section 366.26.1 Mother raises two contentions: first, the Contra Costa County Children and Family Services Bureau (Bureau) did not provide her with reasonable reunification services; and second, the juvenile court erred in concluding Mother failed to “make substantive progress in a court-ordered treatment plan.” (§ 366.21, subd. (e)(3).) We reject the first contention but find merit in the second. The “substantive progress” test under section 366.21, subdivision (e)(3), is a

Further unspecified statutory references are to this code.

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