In Re Silvia R.

INTRODUCTION

Silvia R. (Mother) appeals from a disposition order as to her daughter, also named Silvia R. (Silvia). Mother contends that the juvenile court did not have jurisdiction to include in the disposition order a requirement that Silvia’s stepfather and her adult brother, both of whom sexually abused Silvia, participate in sexual abuse counseling for perpetrators.

Disagreeing with In re Venus B. (1990) 222 Cal.App.3d 931, 935 [ 272 Cal.Rptr. 115 ] (Venus B.), we hold that when the child is removed from the parent’s home, Welfare and Institutions Code section 362, subdivision (c), does not authorize the juvenile court to order other relatives with whom the child is not placed to participate in counseling or education programs. Rather, Welfare and Institutions Code section 361, subdivision (c), authorizes the court to impose on the parent, as a condition of the disposition plan for reunification with the child, that the parent demonstrate to the court’s satisfaction that the parent can protect the child. (§ 361, subd. (c)(1).) Further, when the child has been the victim of sexual abuse by other relatives, the court has the authority to order that the parent must…