In re M.M.
Los Angeles County Department of Children & Family Services v. A.W.
Opinion
Opinion
Perluss, J.
A.W. appeals from the juvenile court’s jurisdiction findings and disposition order adjudging her four-year-old son, M.M., a dependent of the juvenile court, removing him from A.W.’s care and custody and placing him with the Los Angeles County Department of Children and Family Services (Department) for suitable placement. A.W. contends the juvenile court erred in proceeding with the contested jurisdiction and disposition hearing in her absence and there was, in any event, insufficient evidence M.M. was at substantial risk of serious physical harm. The Department concedes A.W. had a right to be present at the jurisdiction and disposition hearing but argues “any alleged errors” were harmless. We reverse.
FACTUAL AND PROCEDURAL BACKGROUND
1. The Dependency Petition and the Detention Report and Hearing
In a petition filed May 13, 2014 pursuant to Welfare and Institutions Code section 300, subdivisions (b) (failure to protect) and (g) (no provision for support), the Department alleged A.W. had taken M.M. with her when she went to solicit sex and then, while incarcerated on charges of prostitution, failed to make an appropriate plan for his ongoing care and supervision.