In re T.H. CA1/1

CourtCalifornia Court of Appeal
DecidedDecember 23, 2024
DocketA170685
StatusUnpublished

This text of In re T.H. CA1/1 (In re T.H. CA1/1) 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 T.H. CA1/1, (Cal. Ct. App. 2024).

Opinion

Filed 12/23/24 In re T.H. CA1/1 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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

FIRST APPELLATE DISTRICT

DIVISION ONE

In re T.H., a Person Coming Under the Juvenile Court Law.

SOLANO COUNTY HEALTH AND SOCIAL SERVICES DEPARTMENT, A170685 Plaintiff and Respondent, v. (Solano County Super. Ct. No. J45474) W.T., Defendant and Appellant.

W.T., father,1 appeals from juvenile court orders denying his Welfare and Institutions Code section 388 petition2 and terminating his parental rights to T.H. (minor) pursuant to section 366.26. W.T. contends the juvenile court (1) abused its discretion in denying his section 388 petition; (2) erred in declining to apply the beneficial parent-child relationship exception to termination of parental rights; and (3) erred in ruling the Indian Child

1 Mother is not a party to this appeal. All further statutory references are to the Welfare and Institutions 2

Codes unless otherwise indicated.

1 Welfare Act (ICWA; 25 U.S.C. § 1901 et seq.) is inapplicable because the court and the Solano County Health and Social Services Department (Department) failed to comply with the inquiry requirements of ICWA. The Department concedes the asserted ICWA error, and limited remand is appropriate to ensure ICWA compliance. In all other respects, we affirm. BACKGROUND After mother tested positive for methamphetamines during her pregnancy and at birth, the Department filed a section 300 petition alleging a failure to protect (§ 300, subd. (b)). In March 2022, mother submitted on the allegation, and the juvenile court sustained the petition and took jurisdiction over newborn minor. Mother was unsure of the identity of the father. Although she listed her current boyfriend E.C. on minor’s birth certificate, mother was pregnant before she met E.C., and she thought her ex-boyfriend W.T. might be the father. After the jurisdiction hearing but before the six-month hearing, the Department located W.T. (hereinafter father). In its six-month review report, the Department recommended continued reunification services for mother. It also recommended father be elevated to “presumed father” status and be provided with reunification services. The Department reported father wanted minor returned to his care and had started visitation in August 2022. Father had been homeless for eight months but was temporarily living with his girlfriend, and the two were trying to find an apartment. Minor, now eight months old, had been placed

2 with a maternal relative3 since he was two weeks old, and he was “developmentally on target.” In an addendum report, the Department stated father was living with his girlfriend and her father, but he was worried that if his girlfriend’s father learned he had “fathered a child,” it could “jeopardize” his housing situation. He requested support regarding housing resources. He worked two part-time jobs and was “open to taking parenting education classes.” Father’s case plan objectives included obtaining and maintaining stable and suitable housing, parenting education classes, and twice weekly supervised visitation. At the six-month review hearing, the court found father was “not presently able to care” for minor, and it would be detrimental to minor to return him to father. The court granted father reunification services and set the matter for a 12-month review hearing. In its 12-month review report, the Department recommended continued reunification services for father. Father and his girlfriend had been asked to leave her father’s residence and the two were currently renting a room but were unable to have minor live with them. Father had been referred to three programs: Family Navigator Services with an assigned case manager to help him locate low-income housing; Bringing Families Home, which would assist him with a move-in deposit and temporary rental assistance; and Family Preservation services. In following up, the Department left a voicemail message with and sent an e-mail message to the case manager at Family

3 It is unclear from the record whether minor was placed with the maternal great-aunt, the maternal aunt, or the maternal cousin, as all three titles are used. Regardless, there is no dispute minor remained in the same placement for the entirety of the dependency proceedings, except for a two- week period when he was initially removed from mother. We refer to the relative as the caregiver or care provider.

3 Navigator Services but had not received a response. A social worker at Bringing Families Home stated she had attempted to contact father, but his phone was not accepting calls and that father needed to complete their application to receive rental assistance. The social worker provided father with the social workers’ contact information, and he confirmed he had the information and would reach out. The child welfare supervisor at Family Preservation Services stated they would be closing father’s referral due to his nonresponsiveness and the Department would have to submit another referral on father’s behalf. On inquiry by the social worker, father agreed to reach out to inquire about keeping his referral open. Father was largely in compliance with his parenting education, needing to complete one missed class. Father participated in weekly two-hour supervised visits and had progressed from “supervised to monitored” visitation. Father sometimes needed assistance feeding and changing minor and “instructions on how and when to provide” minor with medicine when he was sick with a cold or teething. Additionally, the care provider “expressed concern” during two visits because father’s girlfriend “did all of the feeding and changing of [minor’s] diaper.” The social worker spoke to father who agreed to “take more responsibility for meeting his son’s basic needs.” During one visit, minor appeared “pleasant” throughout the visit and “seemed to enjoy the interaction.” At another time, he was described as being “distracted.” But father “did well with playing” with and engaging minor. The court found father’s progress toward alleviating the causes necessitating placement was “adequate,” continued minor’s out-of-home

4 placement, ordered six more months of reunification services, and set the matter for an 18-month review hearing.4 In its 18-month review report, the Department recommended termination of reunification services for father. Father had made “adequate” progress in his case plan but the Department was concerned father had not progressed past monitored visitation. Additionally, although father completed parenting education and could communicate what he learned, he “struggle[d] with demonstrating” his lessons during visits and had also not demonstrated he could meet minor’s “basic needs.” For example, the care provider shared that one time minor “had dried feces on his behind” and another time minor had a rash. Father stated he was “unaware of this and that the [care provider] does not give him much insight into how to meet his son’s needs.” The provider stated that she helps father by “telling him the essential things to pack in [minor’s] diaper bag, his favorite foods,” and what toys he likes.

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Bluebook (online)
In re T.H. CA1/1, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-th-ca11-calctapp-2024.