Human Resources Agency v. Evelyn W.

Erika W. was removed from the custody of her mother (hereafter appellant), and the juvenile court took jurisdiction over her under Welfare and Institutions Code section 1 300, subdivisions (b), (d) and (j). She was placed in the custody of her father, Charles W., and family maintenance services were provided to him. Reunification services were not provided to appellant. Appellant filed a notice of appeal from the jurisdictional and dispositional orders. Six months later, the juvenile court dismissed the dependency action because Erika was “no longer in need of the supervision of the Juvenile Court.” Appellant also filed a timely notice of appeal from the dismissal order.

*474 On appeal, appellant contends that the juvenile court’s orders should be reversed because the juvenile court erred in (1) restricting appellant’s cross-examination of the social workers, (2) permitting Erika to testify, (3) concluding that it would not be detrimental to Erika to place her in her father’s custody, and (4) denying reunification services to appellant. In the published portion of this opinion, we conclude that the juvenile court had discretion under section 361.2 to deny appellant…