S.O.

M.B. (the child), the infant son of S.O. (the mother), was detained, declared a dependent, and placed in foster care. Over the course of the dependency, the mother repeatedly yelled and cursed at employees of San Bernardino County Children and Family Services (the Department), including not only social workers, but also security guards and receptionists. She tied up the Department’s phone lines with harassing and hangup calls. She also threatened employees of the Department; eventually, she pleaded guilty to one count of making a criminal threat. (Pen. Code, § 422.)

Shortly after the six-month review hearing, a therapist told the assigned social worker that the mother had threatened to shoot the social worker. In response, the Department applied for an injunction prohibiting the mother from contacting its employees, except through her counsel. The application was based in part on hearsay, including the therapist’s statements, as set forth in a declaration by the social worker.

The juvenile court issued the requested injunction, although it allowed the mother not only to contact the Department through her counsel, but also to *1061 contact her assigned social worker in…