In re J.D. CA4/1

DISCUSSION

I

Reasonableness of Reunification Services

A. General Legal Principles

The purpose of a reunification plan is "to overcome the problem that led to

removal in the first place." (Blanca P. v. Superior Court (1996) 45 Cal.App.4th 1738,

1748.) "Each reunification plan must be appropriate to the particular individual and

based on the unique facts of that individual." (In re Misako R. (1991) 2 Cal.App.4th 538,

545 (Misako).) To support a finding of reasonable services, "the record should show that

the supervising agency identified the problems leading to the loss of custody, offered

services designed to remedy those problems, maintained reasonable contact with the

parents during the course of the service plan, and made reasonable efforts to assist the

parents in areas where compliance proved difficult . . . ." (In re Riva M. (1991)

235 Cal.App.3d 403, 414.)

"The standard is not whether the services provided were the best that might be

provided in an ideal world, but whether the services were reasonable under the

circumstances." (Misako, supra, 2 Cal.App.4th at p. 547.) The remedy for failing to

offer or provide reasonable services is to extend the…