Brent L. v. Superior Court CA4/3

CourtCalifornia Court of Appeal
DecidedMarch 16, 2016
DocketG052991
StatusUnpublished

This text of Brent L. v. Superior Court CA4/3 (Brent L. v. Superior Court CA4/3) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brent L. v. Superior Court CA4/3, (Cal. Ct. App. 2016).

Opinion

Filed 3/16/16 Brent L. v. Superior Court CA4/3

NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FOURTH APPELLATE DISTRICT

DIVISION THREE

BRENT L.,

Petitioner,

v.

THE SUPERIOR COURT OF ORANGE G052991 COUNTY, (Super. Ct. No. DP025633) Respondent; OPINION ORANGE COUNTY SOCIAL SERVICES AGENCY et al.,

Real Parties in Interest.

Original proceedings; petition for a writ of mandate/prohibition to challenge an order of the Superior Court of Orange County, Gary L. Moorhead, Judge. Petition denied. Sharon Petrosino, Interim Public Defender, Laura Jose, Assistant Public Defender, Rachel A. Novak and Dennis M. Nolan, Deputy Public Defenders for Petitioner. Nicholas S. Chrisos County Counsel and Karen L. Christensen, Deputy County Counsel for Real Party in Interest Orange County Social Services Agency. Law Office of Harold LaFlamme and Tina Stevens for the Minor. * * * I. BACKGROUND In 2014, then four-year-old Wyatt and his younger half-brother Johnny were living with their mother B.N., and Johnny’s father, Robert, in a motel on Lincoln Avenue, a major thoroughfare in west Orange County. B.N. and Robert had married in June of 2013. On November 1, 2014, someone noticed Wyatt and Johnny were alone and unsupervised, and called the police. The police found B.N. and Robert asleep in their motel room. Police also found drug paraphernalia in the room, and both admitted using heroin the night before. Wyatt and Johnny were taken into protective custody by the police. A detention hearing was held five days later, at which the two boys were formally ordered detained at Orangewood Children’s Home. At the detention hearing B.N. told the court Johnny is Robert’s natural son, but Wyatt is the son of petitioner Brent L. Brent was not present at the detention hearing in November 2014, nor was he present at the jurisdictional hearing the next month (Brent was incarcerated at the time). In January 2015, pursuant to stipulation of “all counsel” – which did not include counsel for Brent as one had yet to be appointed for him – the court found that Robert was the “presumed father” of Wyatt. A dispositional hearing was held in March 2015, at which the court approved a case plan contemplating reunification of Wyatt with B.N. and Robert and the children placed in a foster home. The court scheduled a six-month review for August 2015. The six-month review was actually conducted in several stages from August 2015 through December 2015. On September 16, 2015, preparatory to a hearing that would be conducted September 23, the court appointed counsel for Brent, and authorized funds for paternity testing. Brent showed up for the September 23, 2015

2 hearing (the only hearing in this matter where he was physically present). At that hearing, Brent’s counsel told the court Brent had signed a “declaration of paternity” and was “asking to be found [the] presumed [father] as to Wyatt.” At the request of Robert’s counsel, though, the court decided to defer the issue of Brent’s paternity until the next hearing, then scheduled for November 19, 2015. The November hearing was continued to December 16, 2015. By that time, the paternity testing had been completed and confirmed B.N.’s initial report that Brent was indeed Wyatt’s biological father. Concomitantly, at the December hearing, it was also found that B.N. and Robert had made no progress on their own reunification plans, so the court terminated their reunifications services. (The merits of that decision are not before us in this proceeding.) Brent had been released from custody by the December hearing, but he did not attend. His counsel asked for a continuance, and told the court that while Brent had been released from custody sometime after November 19, he had not kept in touch with his counsel, despite being told “multiple” times that contact information was needed after he got out of jail. Though the continuance motion was denied, the trial court expressly deferred any finding that Brent had “biological father status” because he had not “present[ed] himself to the court.” The court scheduled a hearing pursuant to Welfare and Institutions Code section 366.26 on April 12, 2016.1 In a petition for writ of mandate, Brent’s counsel asks this court to do something unusual – vacate the mere deferral of a formal finding of what the record, with the December 2015 DNA tests, now shows to be obvious: Brent is Wyatt’s biological father. Brent’s counsel speculates that Brent may not be allowed to participate at the upcoming April 12, 2016 section 366.26 hearing and, in consequence, is likely to suffer termination of his parental rights. Moreover, says his counsel, absent a finding he is

1 All undesignated statutory provisions are to the Welfare and Institutions Code.

3 biologically Wyatt’s father, Brent’s relatives may not be considered for placement. We deny the petition: any error was harmless even under the strictest standard. II. DISCUSSION A quick primer on the three categories of fatherhood under California law is necessary to understand the extent (and limits) of Brent’s paternal rights. The three categories are, in descending order of strength of paternal rights: presumed, natural, and alleged.

The strongest level of paternal rights is that of a presumed father. Only presumed fathers are entitled to receive reunification services in juvenile dependency proceedings. (In re Zacharia D. (1993) 6 Cal.4th 435, 451 (Zacharia D.) [“we conclude that only a presumed, not a mere biological, father is a ‘parent’ entitled to receive reunification services under section 361.5”].) Significantly, presumed father status does not entail any necessary biological connection to the child, though it is common that presumed fathers are also biological fathers. (See Elisa B. v. Superior Court (2005) 37 Cal.4th 108, 125 [“a person with no biological relationship could be a presumed parent under section 7611”].) While this might at first seem counterintuitive, one of the basic ideas of presumed fatherhood is to preserve existing family units. Section 7611 retains many of the ideas from the old pre-DNA era common law of legitimacy, which made a child born to an existing married couple presumptively legitimate.2 The next level down, that of a natural father, is a man who really is the biological father of the child, but who does not come within a category of section 7611. As the Supreme Court stated in Zacharia D., supra, 6 Cal.4th at p. 449, footnote 15: a

2 We must, however, remark upon a qualification that can undo even presumed father status, at least when there is no biological connection. One case has held that truly reprehensible conduct can actually rebut the “presumption” of fatherhood: In In re T.R. (2005) 132 Cal.App.4th 1202, the court concluded that a man who clearly fell within presumed father status – he had lived with the child and her mother for seven years and had even married the mother within that period of time – still could lose presumed father status based on evidence that he was a registered sex offender and had molested the dependent child. (See id. at p. 1212.)

4 “biological or natural father is one whose biological paternity has been established, but who has not achieved presumed father status as defined in” the Civil Code. Natural fathers may be given reunification services at the juvenile court’s discretion, if the court determines the services would “benefit” the child. (§ 361.5, subd. (a).3) The weakest level of paternal rights is that of an alleged father. Again, our high court in Zacharia D.

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Bluebook (online)
Brent L. v. Superior Court CA4/3, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brent-l-v-superior-court-ca43-calctapp-2016.