In Re Albert T.

The juvenile court denied family reunification services to Peggy L., the mother of Albert T., under Welfare and Institutions Code section 361.5, subdivision (b)(10), [1] which provides that family reunification services need not be offered to a parent of a dependent child if services for a sibling of that child previously had been terminated because the parent failed to reunify with the sibling and the parent thereafter has not made a reasonable effort to treat the problems that led to the sibling's removal. On appeal Peggy contends, although the juvenile court previously terminated reunification services for Albert's brother, Alan C., because Peggy failed to reunify with him, the evidence at the disposition hearing for Albert was insufficient to support the court's implied finding she had not subsequently made a reasonable effort to treat the problems that led to Alan's removal. We agree and reverse.

On October 22, 2003 the Los Angeles County Department of Children and Family Services (Department) detained six-year-old Alan, an emotionally disturbed child (Alan had been diagnosed as having both bipolar disorder and attention deficit hyperactivity disorder),…