In re Destiny S. CA6

I. INTRODUCTION

Parents of a child three or older who has been removed from their custody are generally entitled to reasonable reunification services for the first 12 months after the child’s removal. If after 12 months the juvenile court finds that reasonable services have been offered, but there remains no substantial probability of returning the child to parental custody within the next six months, the court ordinarily terminates services and schedules a hearing to select and implement a permanent plan. When reunification services have been offered to two parents who are not similarly situated, the court may terminate services to one parent and continue services to the other parent without scheduling a permanency planning hearing. That is what occurred in this case. After making the required findings at a 12- month review hearing on July 8, 2013, the court ordered that services continue for the mother of then seven-year-old Destiny S. (Minor) and be terminated for the father, Robert S. (Father). On appeal, Father contends that the juvenile court committed two errors in terminating services to him. First, the court’s conclusion that reasonable services had been offered or…