In re Angelina V. CA2/8, B311979

Fifteen-year-old Angelina reported that her stepfather sexually abused her; mother sent Angelina to live with her father, and in October 2020 the father helped report the abuse to police.
The Los Angeles County Department of Children and Family Services filed a section 300 petition; Angelina was detained from the mother and released to the father pending investigation.
The Department discovered the father had a history of violence and criminal convictions (including spousal battery and other assaults) and past dependency involvement in another child’s case.
During the investigation the father intimidated and distressed Angelina, tried to record a social worker, disobeyed a court order to permit private interviews, delayed treatment for Angelina, and she expressed fear and a desire to live with her mother.
The juvenile court found by clear and convincing evidence that removal from the father’s custody was necessary, placed Angelina with the mother, and ordered monitored visits for the father; the father appealed but the court later terminated jurisdiction while this appeal was pending, and the appellate court nonetheless reached the merits.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether substantial evidence supported removing Angelina from father’s custody	Dept.: Father’s history of violence, intimidation of child and social worker, refusal to cooperate, and interference with services made continued custody likely to cause harm	Father: His lack of cooperation alone cannot justify removal (citing precedent)	Removal affirmed: reasonable factfinder could find it highly probable Angelina would be harmed in his custody given ongoing conflict and conduct
Whether court properly ordered monitored visits for father	Dept.: Father’s controlling, disruptive, and intimidating conduct warranted monitored visits to protect child	Father: Not directly argued beyond contesting restrictions	Affirmed: court acted within discretion to require monitored visits given father’s conduct
Whether appeal was moot after termination of jurisdiction	Dept.: Orders terminated, so appeal moot	Father: Asked court to exercise discretion to decide because orders could affect future proceedings	Appellate court declined to dismiss as moot and exercised discretion to decide merits

Conservatorship of O.B., 9 Cal.5th 989 (standard of review for sufficiency of evidence on clear-and-convincing findings)
In re Jasmine G., 82 Cal.App.4th 282 (refused removal based solely on parental noncooperation in different context)
In re Ma.V., 64 Cal.App.5th 11 (discussing limits of using parental noncooperation to support removal)
In re Ashly F., 225 Cal.App.4th 803 (reversal where court failed to state factual basis for removal and reasonable alternatives existed)
In re D.P., 44 Cal.App.5th 1058 (upholding monitored-visit orders based on parental conduct)
In re Daisy H., 192 Cal.App.4th 713 (discretionary review of moot dependency appeals)