In re K.B. CA2/5, B308059

Minor K.B. was seven weeks old when DCFS opened a dependency investigation after Mother's methamphetamine relapses.
Mother had prior removals for substance abuse, missed drug tests, and failed to comply with a safety plan after an initial relapse.
DCFS removed the children from Mother; Minor was initially placed with Father but a new referral prompted a §300 petition alleging risk from Mother’s substance abuse and Father’s failure to protect.
Father admitted past methamphetamine use and ongoing cravings but consistently tested negative during proceedings; he knew of Mother’s relapses.
Father allowed Mother back into the home, did not immediately report her relapse, and minimized the need for formal treatment—facts the juvenile court found showed a lack of protective ability.
The juvenile court sustained the petition as to Mother and Father, removed Minor from Mother, placed Minor with Father, and ordered reunification services for Father.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Justiciability of Father’s appeal	Mother’s uncontested §300 finding supplies jurisdiction; Father’s challenge is immaterial because one supported ground suffices	Father’s challenge to the finding against him is reviewable	Appeal is not dispositive as to jurisdiction; court affirms jurisdiction based on Mother’s uncontested ground, so Father’s challenge does not change outcome
Sufficiency of evidence for Father’s failure to protect (§300(b))	Father knew of Mother’s relapses, allowed her back, failed to report relapse and minimized treatment—substantial evidence of failure to protect	Father argued he and children were not exposed when Mother returned, he tested negative, and he believed Mother’s relapse was a one‑time slip	Court concluded substantial evidence supported the adverse §300(b) finding against Father, but affirmed jurisdiction primarily because Mother’s uncontested substance‑abuse ground alone justified jurisdiction

In re I.J., 56 Cal.4th 766 (2013) (when multiple grounds alleged, one supported ground suffices for jurisdiction)
In re Alexis E., 171 Cal.App.4th 438 (2009) (same; court need not address each alleged ground once one is supported)
In re I.A., 201 Cal.App.4th 1484 (2011) (dependency primary concern is child protection; finding against one parent can support jurisdiction)
In re Briana V., 236 Cal.App.4th 297 (2015) (jurisdictional finding good against both parents when child is within statutory definitions)
In re Alysha S., 51 Cal.App.4th 393 (1996) (actions of either parent bringing child within statutory definitions can create dependency)
In re L.W., 32 Cal.App.5th 840 (2019) (§300(b)(1) authorizes jurisdiction for substantial risk from a parent’s substance abuse or inability to protect)