San Diego County Department of Social Services v. James J.

James J. and Delores D. appeal a judgment under Welfare and Institutions Code 1 section 300, subdivision (j), declaring their son, Joshua J., a dependent of the San Diego County Juvenile Court and removing him from their custody.

James contends the trial court erred by (1) not allowing him to relitigate the basis of a prior dependency proceeding regarding Joshua’s half-sibling, and (2) admitting into evidence a psychological evaluation of James performed in connection with the prior dependency proceeding. James also contends there was insufficient evidence that reasonable efforts were made to eliminate the need to remove Joshua from the home.

Delores, who had no involvement with the prior dependency proceeding, contends (1) there was insufficient evidence that Joshua was a dependent child, (2) there were no justifiable grounds for removing Joshua from her care, and (3) the department of social services (DSS) failed to make reasonable efforts to keep or reunify Joshua with her.

Procedural and Factual Background

James and Delores had a live-in relationship for about one and one-half years, when Delores gave birth to Joshua on December 26,1993. Joshua was hospitalized…