In re J.E.

The Alameda County Social Services Agency (agency) appeals an order continuing an 18-month review hearing and extending the family’s reunification services for up to 24 months. The agency contends the court erred in extending services based on a finding that the agency had failed to provide reasonable reunification services. Although significant services undoubtedly were provided, we shall affirm the juvenile court’s finding that the services were not reasonably sufficient because they were not tailored to the particular needs of the family arising out of the unique circumstances of the situation. We also conclude that amendments made to Welfare and Institutions Code sections 361.5 and 366.22 do not restrict the court’s authority under section 352 to extend reunification services from 18 to 24 months upon a showing of good cause.

Factual and Procedural Background

On August 9, 2014, the then 14-year-old minor was taken into protective custody by the Oakland Police Department after running away from her mother’s home. The mother had refused to allow her to return home and asked that she be taken into the custody of child protective services.

On August 11, 2014, the…