In Re Patricia E.

Defendant father challenges the order of the juvenile court continuing his minor daughter, Patricia, as a dependent child of the court. The minor was represented by a deputy county counsel who also represented the Sacramento County. Welfare Department (department). We will reverse the order for failure of the trial court to assess the need for the appointment of independent counsel for the minor.

Facts

In August 1978, the minor, Patricia, was made a dependent child of the Kings County Juvenile Court upon a finding that her parental home was unfit. Patricia was born on November 24, 1977. She was first declared a dependent child of the court and placed in a foster home on August 14, 1978. Her home was alleged to be unfit because of neglect and abuse by her parents. She had sustained a skull fracture, two broken wrists, a broken right ankle, contusions and abrasions. (Welf. & Inst. Code, § 300, subd. (d).) She was placed in a foster home. Her brothers were also removed from parental custody.

In June 1979 Patricia’s status as a dependent child was continued but she and her brothers were returned to parental custody. In November 1979 Patricia suffered further severe…