In re Z.S. CA2/2

BACKGROUND

We limit our recitation of the facts to those relevant to the matter before the court. The juvenile court exercised jurisdiction over the children pursuant to a section 300 petition filed in October 2023. The petition alleged the children’s father had recently murdered the children’s two other siblings, and inflicted serious injuries on the surviving children, after Mother allowed Father access to the family in violation of a prior custody order. Father was arrested, the children were detained from Mother and Father and placed in foster care, and the court ordered only monitored visitation for Mother. The court sustained the petition in April 2024. On March 27, 2024, the juvenile court entered an interim order in the adjudication hearing. That order gave DCFS authority to liberalize Mother’s visitation to unmonitored with approval of the court. It also contains the only ICWA finding Mother references in her opening (and only) appellate brief. The juvenile court found ICWA inapplicable on the record then before it.

Undesignated statutory references are to the Welfare and Institutions Code.

2 In February 2025, the juvenile court approved unmonitored visitation…