In re E.H. CA2/8

CourtCalifornia Court of Appeal
DecidedMay 6, 2026
DocketB346546
StatusUnpublished

This text of In re E.H. CA2/8 (In re E.H. CA2/8) 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 E.H. CA2/8, (Cal. Ct. App. 2026).

Opinion

Filed 5/6/26 In re E.H. CA2/8 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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

SECOND APPELLATE DISTRICT

DIVISION EIGHT

In re E.H. et al, Persons Coming B346546 Under the Juvenile Court Law. ______________________________ (Los Angeles County LOS ANGELES COUNTY Super. Ct. No. 19CCJP07130E–J) DEPARTMENT OF CHILDREN AND FAMILY SERVICES, Plaintiff and Respondent, v. LILIANA P.,

Defendant and Appellant.

APPEAL from the findings and order of the Superior Court of Los Angeles County, Juan M. Valles, Juvenile Court Referee. Affirmed. Michelle L. Jarvis, under appointment by the Court of Appeal, for Defendant and Appellant. Dawyn R. Harrison, County Counsel, Kim Nemoy, Assistant County Counsel, and Brian Mahler, Deputy County Counsel, for Plaintiff and Respondent. _________________________ INTRODUCTION Liliana P., mother to six children, challenges the juvenile court’s order that she complete a 26-week domestic violence program for victims. She contends the trial court should have allowed her to address the issue in individual counseling, which was also ordered, instead of compelling her to attend a separate class that created “an undue burden” on her and was “excessive and not necessary.” We affirm. A. Prior Case On November 5, 2019, the Los Angeles County Department of Children and Family Services (Department) filed a dependency petition on behalf of E.H. and her three siblings because of domestic violence between Mother and Father. The petition also alleged Mother failed to protect the children by allowing Father to reside in the home in violation of a criminal protective order that Father was not to have contact with Mother or the child E.H. It was alleged Father had been convicted of threatening a crime with intent to terrorize. A criminal protective order against Father protected Mother and E.H. and allowed peaceful contact between the parents only for the safe exchange of the children and any court-ordered visitation. The protective order was set to expire on December 27, 2025. The juvenile court sustained the allegations, ordered family reunification and maintenance services and on May 24, 2021, closed the case with an exit order granting legal and physical custody of the children to Mother and ordering supervised visitation for Father.

2 B. Current Case Five years later, on January 15, 2025, the Department filed a dependency petition on behalf of (now) six children with the sole allegation that Mother and Father had engaged in domestic violence and Mother had failed to enforce the criminal protective order, subjecting the children to substantial risk of harm. On March 26, 2025, the Department filed a first amended petition. The amended petition alleged Mother and Father have a history of engaging in violent altercations. In 2024, Father threw a cup at Mother which hit one of the children. On a prior occasion, Father pushed mother, inflicting a laceration on her head. Father’s prior criminal history was alleged as well as his history of substance abuse and current use of marijuana and alcohol. Father’s violent conduct in violation of the protective order and substance abuse rendered him incapable of providing regular care for and endangered the children. Mother failed to enforce the protective order and, with knowledge of Father’s substance abuse, allowed him unlimited access to the children, endangering the children. The children’s ages ranged from two months to 11 years old. The children and Mother were interviewed prior to the adjudication hearing. Mother admitted verbal arguments with and cursing but denied domestic violence. Some, but not all, of the children stated they witnessed domestic violence in the home and contradicted Mother’s statements that Father was not permitted in the home. Their statements changed as each was reinterviewed after the detention hearing. Four of the children later stated Father stayed overnight at their home several times a week. One child recanted his earlier observation of domestic violence between the parents while another child elaborated on

3 his observations of his parents hitting and pushing one another while fighting. Mother continued to deny domestic violence, believed the children were lying to DCFS about physical violence in the home, and was not interested in a voluntary case management program because she had completed services in the prior dependency case and Father had done nothing wrong. At the combined jurisdiction and disposition hearing on May 27, 2024, the juvenile court sustained the first amended petition as pled. The court found the parents’ denials not credible, relied on the children’s initial statements supporting the domestic violence allegations in the petition, linked Father’s violent conduct to his ongoing substance use, and found that given the parents’ minimization of the impact of domestic violence, the risk to the children could not be mitigated sufficiently to merit dismissing the allegations of domestic violence. The court declared the children dependents of the juvenile court, ordered them removed from Father and placed with Mother, and granted family maintenance services to Mother and enhancement services to Father. The Department had recommended several separate programs as part of Mother’s case plan. Mother asked the court to order her to participate in individual counseling only where all her issues could be addressed together. Mother argued she was the sole provider of six children and it would be incredibly difficult to timely complete a more comprehensive case plan. In response, the juvenile court struck a parenting program recommended by the Department from Mother’s case plan but ordered her to attend a 26-week support group for domestic violence victims and to attend individual counseling. This appeal followed.

4 DISCUSSION A. Applicable Law Welfare & Institutions Code section 362, subdivision (a), provides that the court “may make any and all reasonable orders for the care, supervision, custody, conduct, maintenance, and support of the child.” Pursuant to section 362, subdivision (d), the court “may direct any reasonable orders to the parents . . . of the child” including to participate in a counseling or education program “designed to eliminate those conditions that led to the court’s finding that the child is a person described by section 300.” (Id., subd. (d).) These statutes “have been broadly interpreted to authorize a wide variety of remedial orders intended to protect the safety and well-being of dependent children.” (In re Matthew M. (2023) 88 Cal.App.5th 1186, 1196.) B. Standard of Review The juvenile court has broad discretion to determine what would best serve and protect the child’s interest and to fashion a dispositional order in accordance with this discretion. (In re Neil D. (2007) 155 Cal.App.4th 219, 225.) The court’s order will not be reversed absent a clear abuse of discretion. (Ibid.) A court exceeds the limits of legal discretion if its determination is arbitrary, capricious or patently absurd. The appropriate test is whether the court exceeded the bounds of reason. (In re L.W. (2019) 32 Cal.App.5th 840, 851.) C. Analysis Here, the issue that brought the family within the jurisdiction of the juvenile court was domestic violence between the parents endangering the physical welfare of the children.

5 Mother does not challenge the juvenile court’s findings in that regard.

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Bluebook (online)
In re E.H. CA2/8, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-eh-ca28-calctapp-2026.