Guadalupe S. v. Los Angeles County Department of Children & Family Services

Appellant Guadalupe S. is the paternal grandfather of Gloria A., who has been declared a dependent child of the juvenile court *479 based on the absence of parental care and support. (Welf. & Inst. Code, § 300, subds. (b) & (g).) Guadalupe challenges the court’s dependency finding and all subsequent findings and orders on the ground that the court lacked subject matter jurisdiction under the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA or Uniform Act) (Earn. Code, § 3400 et seq.). Respondents, Gloria and the Los Angeles County Department of Children and Family Services (DCFS), contend that the court had jurisdiction under the Uniform Act and the DCFS contends that, in any event, Guadalupe lacks standing to challenge the court’s jurisdiction.

We hold that Guadalupe has standing to challenge the court’s subject matter jurisdiction under the Uniform Act. On the merits, we hold that substantial evidence does not support the court’s finding of “home state” jurisdiction under the Uniform Act. We reverse the court’s orders and remand the case with directions to the court to determine whether an alternative basis for its jurisdiction existed under the Uniform…