MELINDA K. v. Superior Court

In this juvenile dependency case, Melinda K. (mother) appeals from the court’s finding at the six-month review hearing that reasonable reunification services had been provided. At the hearing, the court also ordered a continuation of reunification services to which mother had no objection. Because the juvenile court’s order continuing reunification services was not adverse to mother’s interest, we conclude that she is not an aggrieved party and that the finding of reasonable reunification services is not directly appealable. However, because we recognize that such a finding may have negative consequences at subsequent hearings, we also conclude that the finding may be reviewed on a petition for writ of mandate. We therefore treat mother’s appeal as a writ proceeding, and in reaching the merits conclude that substantial evidence supports the juvenile court’s finding and deny the writ.

FACTUAL AND PROCEDURAL BACKGROUND

The minor first came to the attention of the Department of Children and Family Services (the Department) in September 2002. She was nine years old and had been abandoned by her mother. The minor was living with her father’s girlfriend (hereafter the…