Filed 6/5/26 In re C.B. CA4/2 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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 TWO
In re C.B. et al., Persons Coming Under the Juvenile Court Law.
RIVERSIDE COUNTY DEPARTMENT OF PUBLIC SOCIAL SERVICES, E087200
Plaintiff and Respondent, (Super.Ct.No. DPIN2400084)
v. OPINION
K.K.,
Defendant and Appellant.
APPEAL from the Superior Court of Riverside County. Susanne S. Cho, Judge.
Affirmed.
John P. McCurley, under appointment by the Court of Appeal, for Defendant and
Appellant.
Minh C. Tran, County Counsel, Jamila T. Purnell, Assistant County Counsel, and
Julie Jarvi, Deputy County Counsel for Plaintiff and Respondent.
1 In this dependency case, a father appeals the termination of his reunification
services at the 12-month review hearing. He argues no substantial evidence supports
three findings underlying that order: that returning his four daughters to his care would
create a substantial risk of detriment, that he was provided with reasonable services, and
that there was no reasonable probability the children would be returned if the matter was 1 continued to the 18-month review hearing. We affirm.
I. FACTS
Defendant and appellant K.K. (father) has four daughters—C.B. (born 2014), R.K. 2 (born 2017), A.K. (born 2018), and V.K. (born 2020)—with their mother M.B. (mother).
Mother also has a son, Z.B. (born 2023), with a different man. According to father, only
after Z.B. was born did he learn he was not the boy’s father, and after attempts to “work
things out” with mother were unsuccessful, he moved out of the family home.
In March 2024, the five children resided with mother. Plaintiff and respondent
Riverside County Department of Public Social Services (the department) responded to a
report that the maternal grandfather had sexually abused C.B. That alleged abuse was
committed after mother allowed the maternal grandfather to stay with the family
temporarily even though she knew he was a registered sex offender and had a history of
1 Undesignated statutory references are to the Welfare and Institutions Code. 2 Father is C.B’s biological father, but he was not on the birth certificate or present for her birth because mother (born 1998) was a minor at the time and father was an adult (born 1991). He was present for the births of their other children, he is on their birth certificates, and he was living with mother at the time of their births.
2 substance abuse. The department also learned that mother had been leaving the children
at home alone without any adult supervision, and there were concerns about mother’s
own substance abuse and mental health. A social worker who visited the home found it
“was messy and smelled musty.” The children were “disheveled, but without any marks
or bruises.”
The department contacted father, who was living in Nevada. He said he was
willing to care for his children, but he was unemployed and his living arrangement,
renting a room, meant he lacked space for them. He said he had maintained
communication with the children through video chat, but had not seen them in person
since October 2023. He admitted to a “criminal history nine years ago [for] ‘weed’
possession and being with the mother when she was underage.” He and mother engaged
in verbal domestic violence with one another near the end of their relationship.
Mother had told father about C.B. being sexually abused by the maternal
grandfather, and he knew that police were involved. He said he had not known that
maternal grandfather was a registered sex offender. When asked about mother leaving
the children home unsupervised, he “indicated he was not surprised.” He said that when
he was living with mother, and even after he moved out, C.B. would call him when
mother would leave her home alone with the other children, and he would “rush home.”
The last time C.B. had told him about being home unsupervised with the other children
was in November 2023 “when she had her own phone”; now his only communication
with the children is “with [] mother present.” He said he tried to contact law enforcement
3 about the children being left alone, but got “no help.” He said that C.B. had told him that
mother “would be gone for hours and it happens at least three to four times a week.”
Father was concerned that alcohol “gets the best of” mother. He said he would like help
with housing so “he could better care for the children.”
The department filed a dependency petition as to all five children on April 18,
2024, but did not immediately detain them out of mother’s care. About two weeks later,
however, the department filed an amended petition, took the children into protective
custody, and placed them in foster care, after a report that mother again left the children 3 unsupervised and that she had hit R.K. with a belt, causing marks. At the detention
hearing in May 2024, the juvenile court detained the children. It found father was the
presumed parent of the four older children.
The department’s investigation of father’s criminal history showed he had
previously been required to register as a sex offender under Penal Code section 290. He
had been free of that requirement under California law since December 2019, but he
“may be required to register in other jurisdictions.”
The two oldest children recalled witnessing domestic violence between mother
and father. When the social worker asked C.B. to describe father, she said he is “‘really
nice but plays too rough sometimes.’” When asked to explain what that meant, she said
“we just mess around too much,” and did not elaborate further. C.B. also said she would
3 The dependency petition would be amended twice more before the jurisdiction hearing. For our purposes, it is unnecessary to track the changes made by these amendments.
4 tell father what was happening at home when they talked on the phone, but “they did not
always talk.”
Father told a social worker he knew mother was leaving the children alone and she
was using cocaine and alcohol. He said that he knew about the lack of supervision by
February 2024, because the children would tell him two or three times a week that they
were alone. He would tell them to go to a neighbor’s house. Father expressed his belief
the children should be placed in his care because the children had been removed because
of mother’s mistakes, and he did not feel he had done anything wrong.
In June 2024, father moved to North Dakota. He provided the department his new
address.
In July 2024, the children’s caregiver called the social worker about an “ongoing
Zoom visit” between father and the children, during which father was “screaming” at her,
and telling the children that the caregiver had “kidnapped” them so they “are allowed to
misbehave.” When the social worker called father, he “continued to yell,” saying that his
rights were being infringed and that he would be suing her “due to kidnapping his
children.” Father followed up this phone call with text messages in the same vein.
Later that month, mother was sober, having recently checked into an in-patient
treatment program, and she “felt inclined to share information” about father. She said
father would slap the children across the head when he became mad, that he has
threatened to kill himself, and that he blames her for the children being removed from
5 their care. She said that when she and father lived together, he did not care for the
children.
At a July 2024 hearing, the department requested an order authorizing it to obtain
C.B.’s birth certificate from the appropriate Nevada agency, which the court provided
orally and in a minute order.
At the August 2024 jurisdiction hearing, the juvenile court sustained the operative
third amended dependency petition, removed the children from parental care, and ordered
reunification services for both mother and father. The allegations sustained against father
were under section 300, subdivision (b)(1) (failure to protect): “[Father] knew or
reasonably should have known the children’s health and safety were being neglected
while in the care of the mother. The father admitted knowing of the mother’s substance
abuse issues, the poor living conditions of the home, and the children being left
unattended. The father failed to take protective measures or actions to protect the
children, leaving them at continued substantial risk of physical harm.” At the same
hearing, father’s counsel raised the issue that the department had not yet provided father
with his children’s birth certificates. The court confirmed that the department had been
ordered to provide father with the birth certificates, and it should do so.
Also in August 2024, a social worker contacted the county “Human Service Zone”
of the North Dakota county where father lived, and relayed to father information about
available services. Father responded with an email telling the social worker that the
services provided included housing services if he could get the birth certificates of the
6 children. In September 2024, after learning the court’s previous minute order regarding
C.B.’s birth certificate did not “suffice when ordering a birth certificate from the state of
Nevada,” the department made an ex parte request for the necessary order, which the
court signed.
In its February 2025 six-month review report, the department said father was
employed in North Dakota and had recently been promoted. He was involved in a
romantic relationship, though he did not want to disclose his girlfriend’s name. After
some delays, father had completed the parenting classes required by his case plan in
January 2025. The department referred father to resources for completing the general
counseling services required by his case plan. He visited with the children by Zoom,
supervised by their caregiver. The caregiver told the department that in the beginning
father had been rude to her, but he had changed his behavior and had consistently visited.
Father had “completed promises for his children and delivered birthday and Christmas
presents.” At father’s request, his visits were changed from twice a week to once a week
on the weekend to accommodate his work schedule, which had caused him to miss
several visits in January and February 2025.
In February 2025, the juvenile court ordered an evaluation under the Interstate
Compact on the Placement of Children (ICPC) for placing the children with father in
North Dakota. That evaluation was completed in May 2025, with the North Dakota
agency indicating it was willing to approve the home study, but it recommended further
investigation of father’s criminal history by the department before placement. His
7 background check had come back as denied due to previous charges in another state,
which father attributed to “assault/weapon charges over 10 years ago.” The North
Dakota agency recommended the department “gather more specific information on his
charges to make a determination if the children can move.” The department would need
to “maintain custody for at least 6 months to monitor the transition.”
According to the department’s June 2025 12-month review report, father
continued to be employed in the same position, living in North Dakota. The only person
he identified as his support system was his girlfriend, who he said lived in the same
apartment complex. The report says father was renting a bedroom in an apartment from a
friend. Father later testified, however, that this was a misunderstanding; the two-
bedroom apartment was his, and he had rented a room out to “somebody else” for a time,
so that he “would have extra money to buy furniture, such as bunk beds, clothes,
nightstands, things for my kids.” Father’s account is supported by the ICPC home study,
which describes father as living in a two-bedroom apartment, with a mattress on the floor
of one bedroom where father slept, and two sets of twin-sized bunk beds in the other
bedroom.
In April 2025, per his case plan, father completed an intake for general counseling.
Father continued to fail to “understand why the service objectives in his case plan were
assigned as he does not feel responsible for the open dependency.” He nevertheless
participated “for family reunification purposes.” The provider concluded there were “no
8 medically necessary services” recommended, but father “should consider family therapy
to assist with transition, communication, and healthy boundaries.”
On June 11, 2025, father told the social worker he was going to visit California
from June 14 to June 22. The social worker scheduled two visits for father, on June 17
and June 20. Father initially told the social worker that both dates were unacceptable
because he was going to attend a “surfing event” on June 17 and he was going to visit his
grandmother on June 20. Father became “verbally challenging,” expressing that he did
not understand why he could not have unsupervised visits and visits on the weekend and
threatening to return to North Dakota without seeing the children at all if he did not get
unsupervised visits. After an hour of the social worker explaining that the visits had to be
supervised because this was father’s first in-person visit, and that the department was
closed and therefore unable to supervise visits on the weekend, father agreed to a
supervised visit with the children on June 20. The visit, at a restaurant with a play area,
went well.
At a hearing on June 18, 2025, the court granted father’s request for housing
referrals, ordering that if he qualifies he receive “$3,500 in first month’s or deposit and
also other housing referrals that are nonmonetary referrals.” The court authorized
“liberalized visitation coordinated through [the department] and in agreement with the
caregiver,” but reaffirmed that visitation was to be supervised to start.
On June 23, 2025, father told the social worker he would be moving to California.
Because father moved to California, the ICPC referral was withdrawn.
9 Father planned to stay with his father (paternal grandfather) temporarily after
moving to California, but he did not consider paternal grandfather part of his support
system. And, indeed, he does not appear to have stayed there long, as on July 3, 2025,
father asked the social worker not to send a reimbursement check to the paternal
grandfather’s address because “his grandma and his father were telling him that they
would send it back and that [father] was not to contact them.” Father got a job in
California and told the social worker he was looking for housing. On several occasions, 4 the social worker explained to father how the housing assistance referral system worked.
In July 2025, the department submitted a referral for father to a housing assistance
voucher program. On July 28, 2025, however, the social worker learned that father did
not qualify for that program. On August 6, 2025, the department submitted a referral to
another housing assistance program.
At an August 21, 2025 hearing, the social worker told the juvenile court she had
no concerns about father starting unsupervised visits. Father had tested negative for
drugs, he had attended the general counseling intake, he was employed, and there had
been no concerns about his in-person visits with the children in July. The court ordered
father to have weekly unsupervised visits.
4 The department does not “do referrals for specific housing.” It could refer father “to see if he qualifies” for housing assistance programs. Even when the referral is made, however, “funds are not always available.” When funds are available and once the assistance is approved, it can be paid directly to the landlord to cover a deposit or first month’s rent. Or, if father paid “out of pocket,” he could be reimbursed after a review and approval.
10 In September 2025, the department reported father had been laid off from his job.
He had found a new job, but it was only part time and he was “lucky if he gets 8 hours a
week.” He was supplementing that work with “small remodeling jobs” and making
deliveries. The housing assistance program was “in contact” with father and “attempting
to help him find housing.” He said he was having trouble with finding anything because
landlords “want proof of income 2 to 3 times the rent” and he did not have that. Father
told the social worker that if he had approval he could get his old job and apartment in
North Dakota back again, and the bunkbeds for the girls were in storage. He was afraid
he was going to lose his children because he cannot afford to live in California.
In August and September 2025, father had unsupervised visits with the children
five times. The visits generally went well; the children said they had fun and enjoyed
spending time with father. The caregiver reported, however, that the children’s behavior
deteriorated after in-person visits with father began, to the point that “they are not
following any rules or direction.” The children told her that father would talk to them
about the dependency case and would ask them about the caregiver. In the same time
period, the department had opened an “out of home investigation” based on allegations
by the children against the caregiver. The caregiver reported that father had the children
make a “false statement” to the social worker, and that C.B. had come to her and said
“she is sorry that she made up the story because she thought that she would be able to go
live with her dad.”
11 The department’s September 2025 recommendation was that the juvenile court
terminate father’s reunification services. It did not recommend that a section 366.26
hearing be set immediately, as its investigation of the allegations against the caregiver
was still ongoing.
The department acknowledged father’s “efforts to reunify with his children, as
well as the bond he has with them.” But it was only near the end of the 12-month review
period that father moved to California and began in-person visits. Those visits were
limited to weekends due to father’s work schedule, which the department found
“concerning as to [father’s] parenting capabilities” and his ability to manage “the
children’s school, services, medical and dental appointments, and being able to care for
them.” Father also did not “have any support in California that can assist him with his
children.” He had not been able to progress to overnight or weekend visits with the
children because he had not been able to identify a “stable home” where such extended
visits could be conducted, despite the housing referrals he had been provided and the 5 limited “family and friend support” he reported.
5 Father sometimes identified paternal grandfather as someone who “would be willing to help as needed,” but father also said that paternal grandfather would not accept a check being mailed to father, and that paternal grandfather had told father not to contact him. Father also said two “friends,” identified only by first name, were his support system; “Samantha,” who used to babysit the children, and “Rietta,” who was “going to school to be an art teacher” and had “offered her help and support also.” The department apparently was unable to verify that these sources of support would be adequate, particularly given that the four children “require a lot of attention and mental health services.”
12 At the September 29, 2025 12-month review hearing, father testified that he could
get back his apartment in North Dakota and set up the children’s room again “easily.” He
also said his “old job” was still “waiting” for him there, and that he has a “support group”
there. He said the “only thing stopping me is they want me do it here, and just, you
know, economically, I can’t with the way California is right now.”
The juvenile court accepted the department’s recommendation to terminate
father’s reunification services. The court acknowledged that father “loves his children,”
that the children were “obviously . . . very bonded with their father.” The court also
recognized that father’s inability to obtain stable housing in California had been an
obstacle to reunification, hypothesizing during argument that if “he just had a nice four-
bedroom house, things would be a lot different today.” The court found that father was
“not in a position to, basically, take care of [the children] full-time or have them placed
legally at this point, financially too, but legally, in terms of a legal standard.” It had
considered extending services to the 18-month mark, but that deadline was only a month
away, on October 30, 2025, and that was “not enough time to address the issues.” The
court did not immediately set a section 366.26 hearing, ordering the department to
complete its investigation of the allegations against the caregiver “as soon as possible so
that we can resolve the issues that are holding up the permanency plan in this case.”
13 II. DISCUSSION
A. Detriment Finding
Father’s argument that the juvenile court’s detriment finding lacks the support of
substantial evidence rests on the premise that “the record is devoid of evidence that, but
for his inability to afford housing in California that would accommodate him and his
children, Father was incapable of safely parenting his children.” We view the record
differently.
At a 12-month review hearing a juvenile court must return the child “unless the
court finds, by a preponderance of the evidence, that the return of the child to their parent
or legal guardian would create a substantial risk of detriment to the safety, protection, or
physical or emotional well-being of the child.” (§ 366.21, subd. (f)(1).) We review a
court’s finding of detriment for substantial evidence. (Georgeanne G. v. Superior Court
(2020) 53 Cal.App.5th 856, 864.) “Under that standard we inquire whether the evidence,
contradicted or uncontradicted, supports the court's determination. We resolve all
conflicts in support of the determination, indulge in all legitimate inferences to uphold the
findings and may not substitute our deductions for those of the juvenile court.” (Id. at p.
865.)
The jurisdictional allegations sustained against father are based on his failure to
protect his children, despite knowing they were being neglected by mother, both while he
was living with mother and the children and after he moved out. At no point during the
dependency did he take responsibility for that failure, instead blaming mother and
14 believing he had done nothing wrong. Moreover, during the dependency, father’s failure
to act in a protective capacity continued. During virtual visits from out of state, father
tried to undermine the children’s placement by telling them they had been kidnapped by
their caretaker and encouraging them to misbehave. When father visited California in
June 2025, he prioritized a “surf event” over seeing his children in person for the first
time since October 2023 and threatened to leave the state without seeing the children at
all if he did not get unsupervised visits. There is some evidence that even in September
2025, on the eve of the twelve-month review hearing, father was encouraging the
children to make false allegations against the caretaker. Father’s continued failure to take
responsibility for his role in the conditions that led to the dependency, together with his
affirmative actions to undermine the children’s stable foster care placement, is substantial
evidence of a substantial risk of detriment, even setting aside concerns about the stability
of father’s housing situation. Thus, father’s reliance on authority holding that a detriment
finding may not be based solely on a parent’s inability to afford housing is misplaced.
For example, father quotes In re Yvonne W. (2008) 165 Cal.App.4th 1394, 1401-
1402 for the proposition that “[p]roving substantial detriment cannot mean merely
proving that a parent’s living arrangement is less than ideal.” In that case, the juvenile
court had found detriment based on the mother’s “housing situation, citing [the child’s]
expressed fear, anxiety and unhappiness” about living in a long-term shelter for homeless
families. (Id. at p. 1401.) The county welfare department, however, had found the
shelter was “‘appropriate’” housing, and the mother had been “having unsupervised
15 weekend visits at the shelter with no reported problems other than [the child’s] dislike of
the shelter and its residents.” (Ibid.) Father never progressed to unsupervised in-person
visits because he was unable to demonstrate he had obtained similarly safe and
appropriate housing where unsupervised overnight or weekend visits could be conducted,
and because he made himself available for in-person visits only late in the dependency.
Father interprets the court’s acknowledgment of his bonds with the children and
his efforts to get custody, together with its comment that if “he just had a nice four-
bedroom house, things would be a lot different,” as meaning that “the only issue that
remained by the time of the 12-month review was father’s housing.” We view the court’s
comments differently. As discussed, father’s housing circumstances were not the only, or
even the most concerning, obstacle remaining to his taking custody of the children. The
court recognized father’s financial difficulties but emphasized that the “legal standard”
drove its analysis. This simply is not a case where a parent has been separated from his
children “merely because [he is] poor.” (David B. v. Superior Court (2004) 123
Cal.App.4th 768, 792.) Father therefore has not demonstrated the juvenile court’s
detriment finding lacked the support of substantial evidence.
B. Reasonable Services Finding
Father argues the juvenile court’s reasonable services finding is not supported by
substantial evidence because the department failed to provide him with adequate housing
assistance. We are not persuaded.
16 When a court orders reunification services, the department must ensure the
services provided are reasonable. (§ 361.5, subd. (a); Earl L. v. Superior Court (2011)
199 Cal.App.4th 1490, 1501.) Whether the reunification services offered were
reasonable is judged according to the circumstances of each case. (Kevin R. v. Superior
Court (2010) 191 Cal.App.4th 676, 691) “The standard is not whether the services
provided were the best that might be provided in an ideal world, but whether the services
were reasonable under the circumstances.” (In re Misako R. (1991) 2 Cal.App.4th 538,
547.)
The court’s reasonable services finding “must be made upon clear and convincing
evidence.” (In re Alvin R. (2003) 108 Cal.App.4th 962, 971.) We review the finding that
reasonable services were provided or offered for substantial evidence. (Katie V. v.
Superior Court (2005) 130 Cal.App.4th 586, 598.) “In general, when presented with a
challenge to the sufficiency of the evidence associated with a finding requiring clear and
convincing evidence, the court must determine whether the record, viewed as a whole,
contains substantial evidence from which a reasonable trier of fact could have made the
finding of high probability demanded by this standard of proof.” (Conservatorship of
O.B. (2020) 9 Cal.5th 989, 1005.) In other words, “the question before a court reviewing
a finding that a fact has been proved by clear and convincing evidence is not whether the
appellate court itself regards the evidence as clear and convincing; it is whether a
reasonable trier of fact could have regarded the evidence as satisfying this standard of
proof.” (Id. at p. 1009.)
17 Here, there is substantial evidence father received reasonable housing services. In
June 2025, the court authorized father to receive $3,500 in assistance towards first
month’s rent and security deposit if he qualified. By July 2025, shortly after father
moved to California, the department had made the necessary referral and repeatedly
explained to father how the housing assistance program worked. At the end of July 2025,
the department learned father did not qualify for that program, but within days it had
referred father to another program. There is no evidence of anything the department did
that impeded father from benefiting from these programs, nor does he identify any
specific things the department could have done, but failed to do, to assist him in obtaining
adequate housing in California.
Father’s arguments focus on purported failures to provide housing assistance
earlier in the dependency, before he moved to California. For example, in his view, the
department unreasonably delayed in helping him obtain the children’s birth certificates,
which he needed to obtain housing assistance in North Dakota. And he criticizes the
department for this “delay,” characterizing the assistance provided as “too little, too late.”
By father’s own account, however, confirmed by the North Dakota agency’s home study,
he had appropriate housing in North Dakota, a two-bedroom apartment that was set up
with bunkbeds for the children. The ICPC evaluation did not result in unqualified
approval, but not because of any problem with father’s housing, which raised no
concerns. Instead, it was father’s criminal record that caused the North Dakota agency to
18 recommend additional investigation and continuing supervision, and then father’s move
to California caused the ICPC evaluation to be withdrawn altogether.
Moreover, it was father’s own decision to move to California in late June 2025,
not any lack of housing assistance from the department, that left him “having to scramble
to find housing in an unaffordable market” late in the dependency. The department
referred father for housing assistance soon after he arrived in California, and when he
was rejected for one program, it provided a new referral to another program within days.
That is not “wait[ing] until the last possible moment to provide required services,” as
father would have it. It may well have been “too little, too late,” but the fault for that
circumstance was not the department’s. Father’s reliance on cases with different facts, in
which the department was responsible for delays in providing services, is misplaced.
(See, e.g., T.J. v. Superior Court (2018) 21 Cal.App.5th 1229, 1242 [“Maintaining
Mother on a waiting list was not equivalent to ‘providing’ or ‘offering’ services”]; In re
T.W.-1 (2017) 9 Cal.App.5th 339, 346 [department’s case plan was delayed, failed to
identify service providers or provide instructions to parent on how to enroll, and did not
address many of the problems leading to removal].)
Father proposes that we infer the department’s efforts to assist him in finding
affordable housing must have been unreasonable from the fact of his failure to obtain
such housing in California: “Affordable housing is admittedly a difficult problem to
tackle, but where a parent is steadily employed and industrious, as Father was in this
case, it is hard to believe the Department could not find a way to make it work.” We
19 disagree. After his move to California, father briefly had a job he expected to be steady
employment, but did not turn out to be, and he was unable to immediately replace it
except with part-time work for minimal hours, supplemented with “small remodeling
jobs” and making deliveries. Father’s hustle is to be commended, but that is not steady
employment. Also, father’s move to California late in the dependency did not leave the
department much time to “find a way to make it work” before the statutory timelines for
reunification expired. The juvenile court was not compelled to make the inference father
proposes.
Thus, father has not shown the juvenile court’s reasonable services finding lacks
the support of substantial evidence.
C. Probability of Return Finding
Father argues the juvenile court erred in finding there was no substantial
probability the children would be returned to his custody within the statutory timeline.
We find no error.
At a 12-month review hearing a court must return the child “unless the court finds,
by a preponderance of the evidence, that the return of the child to their parent or legal
guardian would create a substantial risk of detriment to the safety, protection, or physical
or emotional well-being of the child.” (§ 366.21, subd. (f)(1).) If the court does not
return the child at the 12-month review hearing, “[t]he court shall continue the case only
if it finds that there is a substantial probability that the child will be returned to the
physical custody of their parent or legal guardian and safely maintained in the home
20 within the extended period of time or that reasonable services have not been provided to
the parent or legal guardian.” (§ 366.21, subd. (g)(1).) To conclude that there is a
substantial probability of return, the court must find (1) consistent visitation, (2) that the
parent “has made significant progress in resolving problems that led to the child’s
removal,” and (3) the parent “has demonstrated the capacity and ability both to complete
the objectives of their treatment plan and to provide for the child’s safety, protection,
physical and emotional well-being, and special needs.” (§ 366.21, subd. (g)(1)(A)-(C).)
We review the juvenile court’s finding there is no substantial probability of return for
substantial evidence. (Kevin R., supra, 191 Cal.App.4th at p. 688.)
Substantial evidence supports the juvenile court’s finding that there was no
substantial probability of return. Father’s argument to the contrary rests on the premise
that his “housing situation” was “the only obstacle remaining for placement,” which we
have already rejected. And there is little if any evidence father was on the verge of
resolving even that issue. Moreover, at the time of the 12-month review hearing, which
was held about 17 months after removal, there was little time remaining to address the
remaining obstacles before the 18-month review hearing. There is no appropriate basis
for us to disturb the juvenile court’s determination.
21 III. DISPOSITION
The order terminating father’s reunification services is affirmed.
NOT TO BE PUBLISHED IN OFFICIAL REPORTS
RAPHAEL J.
We concur:
MILLER Acting P. J.
FIELDS J.