In re R.F. CA4/2

I.

INTRODUCTION

During a jurisdiction/disposition hearing, the juvenile court ordered jurisdiction

over R.F. (born in 2016) and L.F. (born in 2013), removed the children from Father’s

custody based on drug abuse findings, and permitted the children to remain with Mother

on a plan of family maintenance. Father appeals from a post-disposition order and

judgment dismissing the juvenile dependency case and entering exit orders awarding

Mother sole custody, decreasing Father’s supervised visitation, and requiring Father’s

visitation to be supervised by a professional monitor at Father’s expense.

Father contends that he did not receive notice and a meaningful opportunity to be

heard before the juvenile court dismissed the proceedings and entered the exit orders.

Father further argues that the errors were structural, requiring automatic reversal, and, if

not structural, they constitute prejudicial reversible error.

We conclude there is no evidence in the record that Father received proper notice

or an opportunity to be heard before the juvenile court terminated dependency

jurisdiction and imposed the exit orders. In addition, the visitation order is ambiguous as

to…