Santa Clara County Department of Social Services v. Antonio R.

Antonio R. (father) appeals from a dispositional order of the juvenile court placing his son, Jesse C., in foster care (Welf. & Inst. Code, § 300, subd. (a)) and denying reunification services pursuant to Welfare and Institutions Code section 361.5, subdivision (b)(2). He contends 1) there was insufficient evidence to support the order, and 2) the trial court committed reversible error by combining the jurisdictional and dispositional hearings, contrary to section 358, subdivision (c). The Santa Clara County Department of Social Services (DSS) responds that this appeal should be dismissed as moot in view of the intervening termination of appellant’s parental rights. (Civ. Code, § 232, subd. (a)(6).) 1 We agree.

Procedural History

Jesse C. was taken into protective custody in January 1988 when he was one day old. A petition was thereafter filed under Welfare and Institutions Code section 300, subdivision (a), alleging that the parents had a history of “extreme family conflict” resulting in physical altercations and frequent separations, on one occasion resulting in appellant’s arrest for domestic violence. The petition further alleged that the parents were unable to…