L. A. Cnty. Dep't of Children & Family Servs. v. A.S. (In re J.P.)

*617 When a dependency court declares children dependent and removes them from a parent's custody, is it within the court's discretion to order a reunification plan with which the parent indisputably *618 cannot comply due to a language barrier? We find the answer rather self-evident and conclude that such a plan, doomed to fail, is an *750 abuse of discretion. We therefore reverse the dispositional order that imposed it.

FACTUAL AND PROCEDURAL BACKGROUND

1. Family History

In 2013, father A.S. (father) immigrated to the United States, from Myanmar, with two of his four children. His wife, A.Z. (mother), and their other two children, remained in a refugee camp in Thailand, awaiting permission to immigrate and rejoin the family. Father speaks only Burmese or Karen. 1

When father came to the United States with two of his daughters, the divided family lived with paternal great uncle (uncle) and several other relatives. Uncle tried to help father get on his feet, but was stymied by father's drinking and lack of interest. Uncle signed up father for English as a Second Language (ESL) classes, but father refused to attend. Uncle obtained a job for father, which father lost because he…