In Re Christina A.

Good Law
111 Cal. Rptr. 2d 310·91 Cal. App. 4th 1153
Court of Appeal of CaliforniaAugust 27, 2001C036360California4,105 words

Opinion

Opinion

Christina A. (the minor) appeals from a juvenile court order adjudging her a dependent child and setting a status review hearing. (Welf. & Inst.Code, §§ 300, 358; further section references are to this code unless otherwise specified.)

Her claim of error involves the timing of the six-month review hearing after a dependent child under the age of three has been removed from parental custody and reunification services have been ordered. (§§ 361.5, subd. (a), 366.21, subd. (e).) Unfortunately, the applicable statutory language appears to lack consistency as a result of amendments made in 1998. [1]

Section 366.21, subdivision (e) refers to the six-month review hearing being "held six months after the initial dispositional hearing . . . ." (Italics added; see also, § 366, subd. (a)(1) ["The status of every dependent child in foster care shall be reviewed . . . no less frequently than once every six months, as calculated from the date of the original dispositional hearing . . . ."], italics added.)

But in section 361.5, subdivision (a)(2), the Legislature has provided that, for a child who was under the age of three when the child was initially sremoved from the…

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