Trinity County Department of Social Services v. Cynthia V.

In this case involving dependency proceedings brought under Welfare and Institutions Code section 300, we discuss when the time for filing a notice of appeal from an order begins to run. (All further statutory references are to the Welfare and Institutions Code unless otherwise indicated.)

Procedural Background

In this published portion of the opinion, we recite only those facts necessary to determine the timeliness of the appeal. Since we conclude the appeal is timely, in an unpublished portion we consider the appeal on the merits and hold that substantial evidence supports the trial court’s order.

Before March 1988 the minor’s parents had commenced an action to dissolve their marriage, and physical custody of the minor had been awarded to the mother in that action.

While the marital dissolution action was pending, the minor had also been made a dependent child of the juvenile court under subdivision (a) of section 300. The juvenile court ordered placement of the minor with his father.

On March 11, 1988, the juvenile court conducted a six-month review hearing. (§ 364, subd. (d).) Exercising its authority under section 362.4, 1 at *1334 the hearing the court ordered…