San Diego County Health & Human Services Agency v. Jeffrey L.

Jeffrey L. (Jeffrey or father) appeals orders under the Welfare and Institutions Code 2 placing his children, Luke M. and Lenay M., with their paternal aunt and uncle, rather than with him, pending reunification with the children’s mother, Kathy M. (Kathy or mother). He *1416 contends (1) the court improperly considered the statutes relating to sibling relationships when making its decision; (2) the court’s ruling violated his substantive due process rights by placing sibling rights over parental rights; (3) substantial evidence did not support the finding under section 361.2 that the children would suffer detriment if placed with him; (4) the court abused its discretion by requiring Interstate Compact on Placement of Children (ICPC) approval before placing the children with him; and (5) the court did not order appropriate reunification services for him. For the reasons set forth in this opinion, we reject his arguments except as to the issue of reunification services. The parties agree Jeffrey is entitled to appropriate reunification services. Accordingly, we reverse the orders in part and direct the court to hold a new dispositional hearing for the limited purpose of…