C.G.
San Diego County Health & Human Services Agency v. C.G.
Opinion
Lead Opinion
McConnell, J.
*98 Opinion
We affirm judgments in which the court assumed jurisdiction over C.G.’s children, Lana S. and Landon S., based on C.G.’s drug use and the presence of drug paraphernalia in the home; removed them from her custody; and denied her reunification services. Contrary to C.G.’s contention, the court’s jurisdictional and dispositional findings, and the denial of reunification services, are supported by substantial evidence.
A preliminary issue on the denial of reunification services is a matter of statutory construction. Under Welfare and Institutions Code section 361.5, subdivision (b)(10) and (11), 1 a parent is not entitled to services if the juvenile court finds by clear and convincing evidence that in a prior dependency case the parent failed to reunify with a sibling or half sibling of the child in the current proceeding, and “has not subsequently made a reasonable effort to treat the problems that led to removal” of the sibling or half sibling. (Id., subd. (b)(11), italics added.) The issue is whether the italicized language refers only to the problems alleged in the prior dependency petitions, physical abuse and domestic violence, or extends to a chronic problem…