In re A.A. CA3

CourtCalifornia Court of Appeal
DecidedApril 27, 2026
DocketC103998
StatusUnpublished

This text of In re A.A. CA3 (In re A.A. CA3) 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
In re A.A. CA3, (Cal. Ct. App. 2026).

Opinion

Filed 4/27/26 In re A.A. CA3 NOT TO BE PUBLISHED

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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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 THIRD APPELLATE DISTRICT (San Joaquin)

In re A.A., a Person Coming Under the Juvenile Court C103998 Law. (Super. Ct. No. STK-JD-DP- SAN JOAQUIN COUNTY HUMAN SERVICES 2025-0000131) AGENCY,

Plaintiff and Respondent,

v.

A.W., Defendant and Appellant.

Appellant A.W. (mother) appeals the juvenile court’s dispositional orders removing newborn Alex A. (the minor) (Welf. & Inst. Code, § 361, subd. (c))1 and bypassing mother for reunification services (§ 361.5, subd. (b)(6)). She contends the court erred in detaining the minor at the initial hearing and in finding mother waived her right to contested hearing/trial on the jurisdiction/disposition through her nonappearance. She also contends substantial evidence does not support the court’s removal findings or

1 Further undesignated statutory references are to the Welfare and Institutions Code.

1 the section 361.5 subdivision (b)(6) bypass. Disagreeing, we affirm the orders of the juvenile court. FACTUAL AND PROCEDURAL BACKGROUND On April 17, 2025, the minor was placed in protective custody by the San Joaquin County Human Services Agency (Agency) pursuant to a warrant following his premature birth the week before. Mother’s oldest child, I.H., was removed as an infant in 2018 following suspicious injuries and adopted by a relative. Mother’s next child, M.A., was also removed as an infant in 2024. We describe those two cases in detail in our Discussion, post. Mother reported having all necessary supplies to care for the minor, and that she had not used marijuana for a year or methamphetamine for three years. She and the minor tested negative for drugs, and the nurse had no concerns with mother’s interactions with the minor; mother was breastfeeding and pumping and otherwise acted appropriately. Mother told the investigating social worker that she had completed a drug program, parenting classes and therapy (in M.A.’s dependency case), but her services were terminated when she was bypassed. Maternal great-grandmother offered to allow mother and the minor to live with her if needed. While acknowledging the extensive services completed by mother in M.A.’s case, the report identified mother as a high risk because of her failure to acknowledge the severe injuries suffered by I.H. six years before and her inconsistent explanations for those injuries. The Agency recommended out-of- home placement. The petition alleged the minor fell within the provisions of section 300, subdivisions (b)(1) and (j). The failure to protect subdivision (b)(1) allegations were that the minor had suffered or was at substantial risk of suffering “serious physical harm or illness as a result of the failure or inability of his or her parent or legal guardian to supervise or protect the child adequately” and/or “by the willful or negligent failure of the parent or legal guardian to provide the child with adequate food, clothing, shelter, or

2 medical treatment.” The facts supporting these allegations pertaining to mother were based solely on I.H.’s and M.A.’s cases. The abuse of sibling (subdivision (j)) allegations stated that the minor’s “sibling has been abused or neglected, as defined in subdivision (a), (b), (d), (e), or (i)” and there was “a substantial risk” that the minor would “be abused or neglected, as defined in those subdivisions.” The supporting factual allegations relied upon I.H.’s and M.A.’s cases. At the April 2025 initial hearing, mother objected to detention in light of the undisputed “significant strides to change her life,” including sobriety and therapy. The juvenile court referenced I.H.’s “absolutely life-threatening non-accidental injuries that occurred previously” and mother’s only recent acceptance of how they occurred, and detained the minor, finding probable cause that he would be at risk of substantial danger and that no reasonable means could prevent his removal. But the court acknowledged mother’s efforts and honesty, telling her that it was only the beginning of the case and referred her to drug court, granting her liberal supervised visitation. The Agency’s jurisdiction report filed May 1, 2025, attached records related to the siblings’ previous dependency cases and recommended the juvenile court find the allegations true based solely on those cases. Mother attended the originally scheduled jurisdiction hearing on May 8, 2025. Her counsel requested the jurisdiction and disposition hearings be held together, and the court continued the combined hearing to June 3, 2025. The court ordered mother to appear, stating the date, time, and place of the hearing three times, and warning her counsel to “make sure that she’s here” because “if she’s not here, the hearing will go forward without her.” On June 2, 2025, the Agency filed a disposition report recommending bypass pursuant to section 361.5 subdivision (b)(6). Mother had failed to respond to the social worker’s attempts to interview her and had texted the social worker stating verbatim in pertinent part: “ ‘I have been completely open and upfront with CPS about everything in my past how I struggled with addiction but got clean on my own so I could still be in my

3 son’s life but it got twisted up into a bunch of dishonest false allegations and used to keep me from him and now two siblings doctor said I would never have for no reason.... I don’t trust anyone from the agency anymore really don’t understand I’m not guilty of wrong doing I thought I did everything right that any good mom would do in best interest of their children. I just have to step back and take a break it’s too hard I feel overwhelmed with to much hurt and devastation.’ ” Certificates of completion and progress notes showing mother had finished various services in M.A.’s case were attached to the disposition report. But the social worker opined the minor could not be safely maintained in mother’s home given the prior dependency cases and lack of contact with the social worker, recent dismissal from drug court for nonparticipation, and failure to contact the assigned service providers. She had also missed two scheduled visits. The social worker noted “[i]t seems that [mother] may have just given up, believing that this case would result in the same decision as the prior case involving, [M.A.], and therefore made the decision to not participate in any services in an effort to reunify. Thus, leaving the agency with no other option other than to have to make that exact decision.” “[M]other’s continued denial and deflection causes the undersigned to believe that the minor, … could be at risk of suffering harm if he were returned to the care of his mother.” Mother failed to appear at the June 3, 2025, jurisdiction/disposition hearing; her counsel entered a general objection to jurisdiction and asked that disposition be continued as counsel did not know mother’s position, given her absence. The juvenile court found mother had received proper notice and had waived her right to trial and took jurisdiction of the case based on the “factual basis contained within the jurisdiction report.” The court continued the disposition hearing. Mother did not appear at the continued hearing held on June 17, 2025. The juvenile court found notice had been given; counsel for mother indicated when asked that counsel “had an opportunity to speak with my client’s mother but not with my client.”

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Bluebook (online)
In re A.A. CA3, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-aa-ca3-calctapp-2026.