Santa Clara County Department of Family & Children's Services v. William C.

William C. appeals from an order denying him reunification services in dependency proceedings concerning Angelique C. The juvenile court relied exclusively on the reunification bypass provision in Welfare and Institutions Code section 361.5, subdivision (b)(ll), which permits the court to bypass reunification services if a parent’s relationship with a sibling of the minor has been permanently severed. 1 Appellant contends that this provision does not apply to a parent who has voluntarily relinquished parental rights to the sibling. He further contends that there was insufficient evidence to support the bypass findings, that the trial court applied the wrong burden of proof, that because the trial court continued the disposition hearing more than six months past the detention the court should have ordered reunification services, and that the court abused its discretion in not ordering services. We affirm.

FACTS AND PROCEDURAL BACKGROUND

In January 2002, the San Jose Police Department placed 16-month-old Angelique in protective custody. Her mother, Ms. J., “flagged down” the police and told them that she was mentally ill and did not know when she had *513 last taken her…