In re K.M. CA2/4, B258393

T.G., stepdaughter of father, reported years of sexual abuse by father against her starting when she was about nine.
DCFS investigated; safety plan required father to move out and have no contact with children; T.G. to live with her biological father.
T.G.’s allegations led to a petition under WIC 300(b)(1), (d)(1), (j)(1) alleging abuse of T.G. and risk to K.M. and C.M.
The juvenile court sustained the petition, removed K.M. and C.M. from father, and ordered various rehabilitative services and monitored visitation.
Father challenged only the jurisdictional findings, arguing lack of substantial evidence for jurisdiction under subdivision (j).
Appellate court affirmed jurisdiction under subdivision (j), based on severity and scope of T.G.’s abuse and risk to siblings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether substantial evidence supports jurisdiction under 300(j) for K.M. and C.M.	R.M.’s abuse of T.G. created substantial risk to siblings.	No direct abuse proven for K.M./C.M.; risk not established.	Yes; substantial evidence supports jurisdiction.
Whether abuse of a sibling can sustain jurisdiction under 300(j) without direct abuse of the siblings.	Family dynamics and severity justify risk to others in same home.	Jurisdiction should rest only on abuse of the targeted child.	Yes; abuse of T.G. supports jurisdiction over K.M. and C.M.

In re I.J., 56 Cal.4th 766 (Cal. 2013) (broadly supports considering totality of circumstances under 300(j))
Los Angeles County Dept. of Children & Family Services v. Superior Court, 215 Cal.App.4th 962 (Cal. App. 2013) (sibling abuse can support jurisdiction over another child)
In re Janet T., 93 Cal.App.4th 377 (Cal. App. 2001) (distinguishes jurisdiction under different subdivisions)