In re N.F. CA2/3, B337789

Najam F. (father) was incarcerated for most of minor N.F.’s life, with a history of domestic violence involving N.F.’s mother and other women.
Allegations included physical assaults on mother in N.F.’s presence, biting mother while trying to take N.F., and suspected property destruction/arson.
Father doubted his paternity, requested a paternity test, and was ultimately found to be N.F.’s biological (not presumed) father.
Mother participated in court-ordered services and safely regained custody of N.F.; father did not complete his required services due to incarceration.
The juvenile court terminated jurisdiction, gave mother sole legal and physical custody, and, due to a protective order, declined to grant father visitation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether biological father is entitled to visitation after dependency ends	Father not entitled due to lack of presumed status and protective order	Father’s minimal efforts and paternity test support some visitation/involvement	No visitation ordered; court did not abuse discretion

In re Zacharia D., 6 Cal.4th 435 (Cal. 1993) (Biological fathers are not entitled to reunification services or visitation unless they are presumed fathers)
In re Stephanie M., 7 Cal.4th 295 (Cal. 1994) (Abuse of discretion standard for reviewing dependency court orders)
In re A.C., 197 Cal.App.4th 796 (Cal. Ct. App. 2011) (Juvenile court has discretion to make visitation orders upon terminating dependency jurisdiction)
In re Elijah V., 127 Cal.App.4th 576 (Cal. Ct. App. 2005) (No abuse of discretion where services were denied to a biological father with no relationship and a violent history)