Bridget A. v. Superior Court

*295 Opinion

Absent extraordinary circumstances, at the 18-month

permanency review hearing held pursuant to Welfare and Institutions Code section 366.22 1 the juvenile court either orders the return of a dependent child to parental custody or terminates reunification services and sets a hearing for the selection and implementation of a permanent plan pursuant to section 366.26. (§ 366.22, subd. (a); Cal. Rules of Court, rule 5.720(c)(1) & (3); 2 see In re Elizabeth R. (1995) 35 Cal.App.4th 1774, 1788 [ 42 Cal.Rptr.2d 200 ].) If the juvenile court determines there would be no substantial danger to the child if he or she were returned home provided there is continued supervision by a social worker and the ongoing provision of reasonable support services to preserve the family, is such supervised return an option available to the court? Or are the only alternatives returning the child and terminating dependency jurisdiction, on the one hand, or terminating reunification services and setting a section 366.26 hearing, on the other hand?

In this case the Los Angeles County Department of Children and Family Services (Department) recommended at Bridget and Christopher A.’s 18-month…