Los Angeles County Department of Children & Family Services v. Shadonna C.

We granted review in this case to determine whether the juvenile court correctly disqualified the Children’s Law Center of Los Angeles (CLC) from representing Charlisse C., a minor, in this dependency action. CLC is a publicly funded, nonprofit law office that represents parties in the Los Angeles County Juvenile Dependency Court. It currently comprises three units: a core unit, known as Unit 1, and two conflict units, known as Units 2 and 3. Unit 3 undertook to represent Charlisse in this action, which arose when a juvenile dependency petition was filed under Welfare and Institutions *150 Code section 300 1 alleging in part that Charlisse was at substantial risk of being abused or neglected due to the emotional and mental health problems of her mother, Shadonna C. Shadonna is a former client of CLC’s Unit 1 (or its predecessor). Although finding no actual conflict of interest and no improper disclosure of confidential information, the juvenile court, citing Castro v. Los Angeles County Bd. of Supervisors (1991) 232 Cal.App.3d 1432 [ 284 Cal.Rptr. 154 ] (Castro) and People v. Christian (1996) 41 Cal.App.4th 986 [ 48 Cal.Rptr.2d 867 ] (Christian), found that an erosion of…