Trinity County Department of Health & Human Services v. Dan C.

In this appeal, we consider whether the juvenile court has the authority to terminate the reunification services of a parent in a child dependency case prior to the expiration of the six-month period from the time a child has entered foster care. Dan C. (appellant), the father of two children, Aryanna and Isaiah (the minors), whose services were ended after less than three months had elapsed and whose parental rights to the minors later were terminated, contends that, once granted, reunification services may not be ended prior to the six-month review hearing, absent the filing of a petition for modification by the child protective services agency.

We conclude the juvenile court has the statutory authority, on a proper record and after conducting a hearing, to exercise its discretion and terminate reunification services at any time. In doing so, the court must consider all of the circumstances before it, and its determination must be based on a careful exercise of its discretion. In this case, we conclude that the juvenile court properly terminated appellant’s reunification services approximately three months before the six-month time period elapsed. Accordingly, we…