Los Angeles County Department of Children & Family Services v. Robert A.

Robert A. appeals an order of the juvenile court terminating his parental rights with respect to P.A. We conclude the juvenile court erroneously denied Robert A. family reunification services on the basis his whereabouts were unknown, without first requiring the Los Angeles County Department of Children and Family Services (DCFS) to provide a completed declaration of due diligence. However, Robert A. forfeited the right to raise this issue on appeal by failing to raise it in the juvenile court. We further conclude the juvenile court made findings of parental unfitness sufficient to support the order terminating Robert A.’s parental rights. Because each of Robert A.’s assignments of error lacks merit, we affirm the order terminating parental rights.

FACTS AND PROCEDURAL BACKGROUND

1. Detention of P.A. and her siblings.

On December 30, 2004, DCFS filed a dependency petition with respect to three-year-old P.A. and her half siblings, two-year-old Leslie and infant Destiny after Destiny and mother tested positive for methamphetamine at the time of Destiny’s birth. The children were placed with maternal grandmother, where they had been living with mother prior to DCFS…