San Diego County Department of Social Services v. Dennis F.

In this case we deal with the questions whether California’s jurisdiction over a minor pursuant to Welfare and Institutions Code section 300 continues even where all parties have left the state, and, if such jurisdiction continues, when it is appropriate to relinquish it to the forum which has greater contact with the parties. The object of our concern is Gloria F. (Gloria) who was born on April 15, 1978.

On September 3, 1987, the San Diego County Department of Social Services (Department) filed a petition pursuant to Civil Code 1 section 232 et seq., requesting Gloria be declared free from parental custody and control. In December 1987, Gloria’s mother voluntarily relinquished her parental rights. On February 26, 1988, after a hearing, the trial court granted the petition with regard to appellant, Gloria’s father. It found true allegations of cruel treatment and/or neglect within the meaning of section 232, subdivision (a)(2), and failure to maintain a parental relationship with the child within the meaning of section 232, subdivision (a)(7). The court made these findings although by the time of the hearing all interested parties to the action were residing in the State…