In re J.P. CA2/6, B343849

S.P. (Mother) petitioned for extraordinary writ after the juvenile court bypassed family reunification services regarding her adopted son J.P., following an incident where J.P. witnessed a violent altercation resulting in his father's severe injuries.
Mother and L.B., the child's biological father, argued violently in their home, culminating in L.B. being shot and stabbed in J.P.'s presence.
Police found J.P. with blood on his face and clothes; Mother was charged with felony assault and child endangerment (attempted murder was dismissed).
The Ventura County Human Services Agency detained J.P. and his siblings, placing them with relatives due to the incident and alleged trauma experienced by J.P.
At the jurisdiction and disposition hearing, the Agency recommended bypassing reunification services under Welfare & Institutions Code § 361.5(b)(6); the juvenile court sustained the findings and planned for J.P.'s adoption.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether reunification services should be bypassed under §361.5(b)(6)	Mother argued the Agency failed to prove J.P. would not benefit from services.	Agency argued Mother's actions caused severe harm in J.P.'s presence.	Substantial evidence supported bypass under §361.5(b)(6).
Whether the juvenile court misapplied the burden under §361.5	Mother claimed the court improperly shifted her burden to prove best interest.	Agency maintained all statutory standards and burdens were met.	Court applied correct burdens, following statutory procedure.
Whether substantial evidence supported the finding services would not benefit J.P.	Mother argued evidence did not establish services would not benefit J.P.	Agency emphasized trauma and risk evidenced by the violent incident.	Substantial evidence supported non-benefit to J.P.; order upheld.
Whether comparisons to T.R. v. Superior Court precluded bypass	Mother analogized to T.R., where bypass was reversed for lack of findings.	Agency distinguished the facts; here, there were specific findings and serious injuries.	Court found T.R. inapplicable; here, detailed findings and evidence existed.

Jose O. v. Superior Court, 169 Cal.App.4th 703 (Bypass of reunification services permitted based on court’s discretion given individualized facts and severe child harm.)
Jennifer S. v. Superior Court, 15 Cal.App.5th 1113 (Appellate standard for reviewing bypass orders is substantial evidence review.)
In re Brian M., 82 Cal.App.4th 1398 (Statutory provisions for bypassing reunification services and the necessity of substantial evidence.)
In re Matthew M., 88 Cal.App.5th 1186 (Substantial evidence standard prohibits reweighing of evidence on appeal.)