In re Sofia M. CA2/2, B334606

The Los Angeles County Department of Children and Family Services (DCFS) filed a dependency petition asserting Sofia M. and her half-sister were at risk due to parental domestic violence.
The juvenile court found the allegations true, declared Sofia M. a dependent, and removed her from her father's (M.M.) custody, placing her with her mother under DCFS supervision.
M.M. was granted only monitored visitation and ordered to participate in domestic violence and parenting programs.
M.M. appealed the court’s jurisdictional findings and dispositional orders.
While the appeal was pending, the juvenile court terminated jurisdiction, awarded sole physical and legal custody to Sofia’s mother, and entered an exit order granting M.M. limited visitation.
M.M. did not appeal the order terminating jurisdiction or the exit order; the appellate court therefore considered whether the original appeal was now moot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Mootness of appeal after dependency case exit	Appeal is moot; no relief	Findings adversely affect custody, visitation, and reputation	Appeal is moot; no effective relief possible
Discretionary review for stigmatizing findings	Not warranted	Seeks relief due to alleged stigma and ongoing effect	Discretionary review not exercised

In re D.P., 14 Cal.5th 266 (Cal. 2023) (clarifies mootness in dependency appeals and test for effective relief)
In re Rashad D., 63 Cal.App.5th 156 (Cal. Ct. App. 2021) (termination of jurisdiction generally makes appeal moot)
In re N.S., 245 Cal.App.4th 53 (Cal. Ct. App. 2016) (effectiveness of relief in dependency appeals)