In re Maya L.

Ashley L. (mother) was arrested for child endangerment after her four-year-old daughter, Maya L., fell from the trunk of a moving vehicle. Maya was subsequently declared a dependent child of the court pursuant to Welfare and Institutions Code section 300 and placed in the custody of her father, Aaron H. (father). At the six-month review hearing, the trial court terminated jurisdiction and entered a family law order providing father physical and legal custody of Maya. Mother appeals, arguing that the trial court applied the wrong legal standard at the six-month review hearing. We affirm.

FACTUAL AND PROCEDURAL BACKGROUND

A. Initial Referral and Detention

1. Events preceding the section 300 petition

Mother and father lived in separate residences and shared custody of their daughter, Maya L., pursuant to family court order. On November 22, 2012 (Thanksgiving Day), the Los Angeles County Department of Children and Family Services (DCFS) received a referral from law enforcement reporting that Maya, then four years old, had been thrown from the trunk of a car. According to the referral, Maya’s maternal aunt had been driving with mother while the child was seated in the rear…