In re W.O. CA4/2

I. INTRODUCTION

A.O. (Mother) and W.O. (Father) are the parents of Al.O., S.O., and We.O. In

July 2024, the children were declared dependents of the juvenile court and formally

removed from their parents’ custody after a contested jurisdictional and dispositional

hearing pursuant to Welfare and Institutions Code1 section 361. The dispositional order

also provided that each parent would be granted separate, weekly supervised visits with

the children.

In October 2024, both Mother and Father filed petitions pursuant to section 388

seeking to modify the visitation order to provide for more liberalized visits. The juvenile

court denied both petitions without conducting a formal evidentiary hearing. Parents

appeal from the orders denying their modification petitions, arguing the juvenile court

erred by denying their petitions without first granting them an evidentiary hearing.

However, while this appeal was pending, the juvenile court conducted a six-month

review hearing pursuant to section 366.21, found that there was a substantial probability

the children would be returned to parents’ custody within six months, granted continued

reunification services, and entered a new…