In re Isaac L. CA2/7, B265121

DCFS detained Isaac after Y.D. alleged past sexual abuse by Father and the family faced multiple petitions under §300 including risk of physical harm and sexual abuse.
Y.D. disclosed to therapists and later to the CSW that Father molested her years earlier; Mother initially did not report or believe it.
Mother reported extensive domestic violence involving Father and E.R.; she admitted fear and the need for domestic violence therapy.
The juvenile court amended the sexual abuse claim to inappropriate touching and found a domestic violence pattern; it ordered Father to participate in counseling and issued other dispositional orders.
On appeal, Father challenged the sufficiency of evidence for jurisdiction under §300(b) based on inappropriate touching; the court reversed the paragraph b-1 finding but otherwise affirmed.
Judicial notice of a May 17, 2016 order showed Isaac and siblings were returned to Mother with family maintenance services and unmonitored visitation for Father.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there is substantial evidence to support jurisdiction under §300(b) based on past inappropriate touching.	Father argues past touching is insufficient to show current substantial risk.	Father contends one historic incident cannot justify ongoing risk.	No substantial evidence for current risk; paragraph b-1 reversed.
Whether the court properly ordered Father to participate in sex abuse and domestic violence programs.	DCFS supports treatment orders to address risk factors.	Father challenges reliance on a single past event and ongoing risk.	Dispositional order requiring participation affirmed; no abuse of discretion.

In re I.A., 201 Cal.App.4th 1484 (2011) (jurisdiction may be based on parental conduct other than the parent appealing)
In re Christopher M., 228 Cal.App.4th 1310 (2014) (consideration of past conduct to support current needs for protection)
In re Alysha S., 51 Cal.App.4th 393 (1996) (single prior incident insufficient for jurisdiction unless future risk shown)
In re Daisy H., 192 Cal.App.4th 713 (2011) (timing and connection of past violence to current risk decisive)
In re J.K., 174 Cal.App.4th 1426 (2009) (context of abuse and continued risk supports jurisdiction in some cases)
In re Briana V., 236 Cal.App.4th 297 (2015) (jurisdiction not dependent on specific underlying petition; can bind parent via dispositional orders)
In re Daniel B., 231 Cal.App.4th 663 (2014) (court may tailor dispositional orders without a new jurisdictional finding)
In re Nia A., 246 Cal.App.4th 1241 (2016) (oral pronouncement controls over minute order; review of jurisdictional findings)