In re P.S.

CourtCalifornia Court of Appeal
DecidedDecember 18, 2024
DocketA169561
StatusPublished

This text of In re P.S. (In re P.S.) 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 P.S., (Cal. Ct. App. 2024).

Opinion

Filed 12/18/24 CERTIFIED FOR PUBLICATION

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIRST APPELLATE DISTRICT

DIVISION TWO

In re P.S. et al., Persons Coming Under the Juvenile Court Law.

ALAMEDA COUNTY SOCIAL SERVICES AGENCY, Plaintiff and Respondent, A169561 v. (Alameda County S.G., Super. Ct. Nos. JD033255-02, Defendant and Appellant. JD033256-02, JD033257-02, JD034930-02)

S.G., is the mother of four children, now aged eleven, nine, seven and five, all of whom were removed from her custody. She appeals a December 20, 2023 order denying a motion she filed in all four cases, before a scheduled 18-month review hearing while she was still receiving reunification services. The motion requested that the juvenile court appoint a psychological expert under Evidence Code section 730 to perform a bonding study. That section authorizes the court to appoint an expert “at any time” before or during trial when, among other circumstances, it appears that expert evidence “may” be required “by any party to the action.” (Evid. Code, § 730.)

1 The juvenile court denied mother’s motion in part on the stated ground that it was improper for the court to appoint an expert to aid mother in her own “defense.” It appears but is not entirely clear that the court also ruled that mother’s request for the study was unripe as a matter of law because it was made during ongoing reunification services rather than in connection with a recommendation to terminate her services. We hold that a parent may request, and the court must consider a request, for the appointment of a psychological expert to aid the parent in her capacity as a party to the dependency proceedings. Court-appointed expert services under Evidence Code section 730 are not limited to those that may be of direct assistance to the juvenile court itself (commonly described as a neutral, court-appointed expert). Rather, section 730 makes clear that the court may, and where merited should, appoint an expert a party requests to effectively present her case. We also hold that it is not categorically premature for a parent who is receiving reunification services to request the appointment of an expert to perform a bonding study during the reunification phase. Rather, the timing of a parent’s request is one among many factors the court may consider in exercising its discretion to consider the parent’s request. Because the court denied mother’s request on one legally erroneous ground and may have denied the request on a ground that is also incorrect, we cannot rule out the possibility it denied mother’s request on legally untenable grounds rather than an informed exercise of discretion consistent with the law. We will vacate the court’s order as to the two older children and remand the matter for a new hearing.

2 BACKGROUND On February 27, 2020, the juvenile court declared mother’s three older children dependents of the court due to severe, ongoing domestic violence their father perpetrated against mother in their presence. It ordered the children to remain in mother’s custody with family maintenance services.1 On July 19, 2022, the court declared mother’s youngest child a dependent on similar grounds, including that mother had continued to allow father access to the home where she resided with all four children and that father continued to engage in domestic violence against mother in the children’s presence. On September 29, 2022, the Alameda County Social Services Agency (Agency) removed all four children from mothers’ custody on a protective custody warrant and placed them into foster care. On October 3, 2022, it filed a supplemental petition alleging the parents had been in continued contact with each other and father had been in contact with the children, despite both a domestic violence restraining order and the juvenile court order limiting father’s access to the children. The petition alleged that mother had disclosed to him the confidential location of her safe house shelter, there had been another episode of domestic violence, and both parents had been arrested together on burglary charges. At the time of their removal, the children were nine, seven, five and two years old. The court sustained the petition, revoked earlier orders placing the children in mother’s home and removed them from her custody.

1 The case was commenced in Los Angeles County and later transferred to Alameda County.

3 The court ordered reunification services for mother (and bypassed them for father). Mother’s case plan required her to participate in a domestic violence program, participate in individual therapy, develop positive support systems and visit with the children. At the six-month review hearing, mother’s reunification services were extended on the Agency’s recommendation, and the Agency was granted discretion to allow her unsupervised visits. At the 12-month review hearing in November 2024, the court extended her services again on the Agency’s recommendation. By the time the 12-month review hearing took place, mother had been attending individual therapy and some domestic violence sessions and had a support network and safety plan in place. However, the Agency was concerned that she hadn’t attended enough domestic violence counseling sessions due primarily to the program having canceled sessions. It was also worried that she might continue to initiate contact with father seeking emotional or financial support. Further, it expressed concern that she needed safe housing and that her visits hadn’t progressed to unsupervised for a variety of reasons, including because of conflict with visiting center staff. All the children missed their mother, and the Agency believed that was negatively affecting them. On December 5, 2024, about three weeks after the 12-month review hearing, mother filed a motion entitled “Motion For Court Appointed Expert To Conduct Bonding Study,” asking the court to appoint a psychological expert under Evidence Code section 730 and pursuant to her constitutional rights as an indigent litigant to present a defense. Her motion identified a licensed psychologist who was available to be appointed, identified his hourly rate and appended a copy of his curriculum vitae. Her papers described the

4 scope of the expert’s proposed work as encompassing subjects relating to “[m]ental status of mother and the minor; [¶] [t]he bond between biological mother and the minor; [¶] [d]etermine the nature and extent of the mother- children relationship and nature of interrelatedness between mother- children; [and] [¶] [o]pinion as to whether terminating the relationship would be detrimental (due to severing a bond) to the [children] even when balanced against the benefit of a stable adoptive home.” Legally, she asserted the expert’s assistance was relevant to potential application of the parental- benefit exception to defend against the termination of her parental rights.2 The motion concluded by asking the court to “appoint an expert to conduct a bonding study so that she may vigorously attempt reunification with her children.” The thrust of her motion was not that the expert’s services were necessary to aid the juvenile court (although her motion asserted that the information would be helpful to the court), but that they were needed to assist her counsel to mount a defense. She argued that the Agency had the benefit of the social worker’s evaluations which she asserted were functionally the equivalent of expert opinion at public expense and thus, to aid in her defense, she too required an expert in order “to refute the social worker’s expert opinion” concerning various subjects. Her motion also addressed the timing. She argued her request for an expert was appropriately made during the reunification phase rather than

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Bluebook (online)
In re P.S., Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-ps-calctapp-2024.