In re Theodore B. CA2/8, B323495

Theodore born in Arizona in July 2021; tested positive for marijuana at birth and Arizona child-welfare referral was substantiated and later closed.
Parents moved from Arizona to California in February 2022 to live with paternal grandparents in Acton; Theodore was enrolled in Medi-Cal and mother obtained work in California.
A May 2022 violent conflict at the grandparents’ home triggered a Los Angeles County Department of Children and Family Services investigation; paternal grandmother reported mother had threatened to leave to Texas with Theodore.
Department obtained a protective custody warrant against mother in June 2022; a dependency petition was filed in California days later alleging Welfare & Inst. Code §300 grounds.
The juvenile court acknowledged a possible UCCJEA jurisdiction question (initially misstated as involving Texas), directed the Department to investigate, but never made UCCJEA findings or held an evidentiary hearing; in August–September 2022 it adjudicated the §300 petition and removed Theodore from mother.
Mother (represented) did not raise UCCJEA jurisdiction or inconvenient‑forum objections below and appealed; the Court of Appeal affirmed, finding any jurisdictional procedural error harmless and the inconvenient‑forum claim forfeited.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether juvenile court erred by failing to hold an evidentiary hearing to decide UCCJEA home‑state / §3421 jurisdiction	Dept.: any UCCJEA objection was forfeited; in any event California had sufficient contacts and any procedural lapse was harmless	Mother: record raised a genuine question whether another state (Arizona, or as she argued possibly a temporary‑absence issue) was home state and the court should have developed the record	Any failure to make UCCJEA findings was harmless — reversal not warranted because mother did not show a reasonable probability a different jurisdictional result would follow
Whether court erred by failing to consider declining jurisdiction as an inconvenient forum (§3427)	Dept.: §3427 is discretionary and was not raised below; issue therefore forfeited	Mother: even if jurisdiction existed, court should have determined whether Arizona was the more appropriate forum	Forfeited — court declined to consider because §3427 is permissive and mother failed to raise it below

In re Aiden L., 16 Cal.App.5th 508 (UCCJEA gives priority to child’s home state; factors for temporary absence and significant‑connection inquiry)
In re L.C., 90 Cal.App.5th 728 (when record objectively raises home‑state question juvenile court must obtain more information)
In re J.W., 53 Cal.App.5th 347 (UCCJEA jurisdictional objections can be forfeited because UCCJEA does not implicate fundamental jurisdiction)
In re Christian I., 224 Cal.App.4th 1088 (procedural UCCJEA errors are subject to harmless‑error analysis)
College Hospital Inc. v. Superior Court, 8 Cal.4th 704 (harmless‑error standard: appellant must show reasonable chance of more favorable result)
In re Marriage of Nurie, 176 Cal.App.4th 478 (temporary‑absence analysis may focus on parental intent and totality of circumstances)
In re Marriage of Sareen, 153 Cal.App.4th 371 (long duration of absence can make finding a temporary absence implausible)