In re G.S. CA2/4, B338546

G.S., a 15-year-old girl, lived with her paternal uncle and legal guardian, William S., and his wife (aunt) before being detained by the Los Angeles County Department of Children and Family Services (DCFS).
DCFS filed dependency petitions alleging physical and sexual abuse of G.S. by William S., and failure by William S. and aunt to provide proper care and support.
William S. moved to dissolve the legal guardianship, and while that was pending, G.S. alleged that William S. had raped her multiple times.
After a combined jurisdiction and disposition hearing, the juvenile court dismissed some counts but sustained allegations of failure to protect, sexual abuse, and no provision for support; the court declared G.S. a dependent and terminated the guardianship.
William S.'s court-appointed appellate counsel filed a no-issues brief, and William S. himself filed a supplemental brief that did not clearly articulate any legal errors.
The Court of Appeal dismissed the appeal, finding no arguable issue and that substantial evidence supported the juvenile court's findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Dependency jurisdiction and findings	Jurisdiction proper based on abuse and lack of care	Claimed abuse by aunt and suggested G.S. retaliated by fabricating claims	Juvenile court findings supported by substantial evidence
Right to independent review with no-issue brief	N/A	Appellant did not meet good cause requirement to brief issues	No independent review required; appeal dismissed

In re Phoenix H., 47 Cal. 4th 835 (Cal. 2009) (No independent appellate review required in dependency appeals absent an arguable issue)
In re Sade C., 13 Cal. 4th 952 (Cal. 1996) (No right to a Wende-type review in dependency appeals when counsel finds no arguable issue)
In re R.V., 208 Cal. App. 4th 837 (Cal. Ct. App. 2012) (Standard for substantial evidence review in dependency jurisdictional findings)