In re M.C. CA2/4, B308648

M.C., born 2011, was detained after mother was involved in a violent incident; child was placed with maternal grandmother (MGM).
Father (R.C.) is a presumed, noncustodial parent incarcerated in Arkansas on a long sentence with a documented history of serious domestic violence dating to 2009.
Mother and MGM reported father had minimal or no contact with M.C. after infancy; M.C. said she did not know her father and only knew he "would hit [mother]."
DCFS recommended bypassing reunification and denying visitation under Welf. & Inst. Code §361.5(e)(1) based on father’s violent history, long incarceration, failure to parent, and lack of bond with the child.
The juvenile court denied father custody, reunification services, and visitation, finding visitation would be detrimental; father appealed only the visitation denial.
The Court of Appeal affirmed, concluding the court did not abuse its broad discretion in denying visitation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the juvenile court abused its discretion by denying visitation to an incarcerated noncustodial father denied reunification services.	Visitation may be denied where it would be detrimental; evidence showed lack of bond, serious domestic violence, child trauma, and long incarceration.	Visitation should have been allowed (including by phone/video); no direct evidence of absence of bond; transport difficulty to Arkansas not required if remote visits available.	Affirmed. Court may permissibly deny visitation under §361.5(f) when detrimental; record supports denial and father forfeited the transport objection.
Whether the court improperly relied on logistical/transport concerns rather than the child's best interest.	Denial was based on child safety and lack of bond; transport was only one practical consideration among others.	Denial improperly premised on travel difficulty; remote visitation would avoid travel.	Rejected. Father failed to object below to this ground; appellate review finds ample independent evidence supporting denial.

In re A.L., 188 Cal.App.4th 138 (no reunification services required for a noncustodial parent when child remains with custodial parent)
In re J.N., 138 Cal.App.4th 450 (visitation is not integral when parent not participating in reunification; court may deny visitation if detrimental)
In re Korbin Z., 3 Cal.App.5th 511 (discusses permissive nature of visitation for nonreunifying parents)
In re Kayla W., 16 Cal.App.5th 409 (juvenile court has broad discretion to craft dispositional orders, including denying visitation)
In re Pedro Z., 190 Cal.App.4th 12 (reunification goal met when child placed with custodial parent and family-maintenance services ordered)
In re T.G., 242 Cal.App.4th 976 (failure to object to specific grounds at disposition generally forfeits the issue on appeal)