L. A. Cnty. Dep't of Children & Family Servs. v. A.S. (In re J.P.), 14 Cal. App. 5th 616

Father, a Karen/Burmese speaker and long-time alcoholic, immigrated to the U.S. with two daughters; children were detained after DCFS found father’s drinking made him unable to supervise them.
DCFS and the court agreed father needed alcohol treatment, 12-step participation, and parenting classes; father pleaded no contest to dependency under Welf. & Inst. Code §300(b).
DCFS repeatedly reported it could not locate alcohol or parenting programs in Burmese and had difficulty communicating with father; limited accommodations (friend interpreter, Google Translate, phone reminders) were used for on-demand testing.
At disposition the court ordered reunification services including a full alcohol treatment program, 12-step program, and parenting, while directing DCFS to assist in locating Burmese/translated programs; father objected that he could not comply given language barriers.
On appeal, father challenged the disposition as an abuse of discretion because the ordered services were impossible for him to meaningfully participate in due to his limited English; the Court of Appeal reversed that portion of the disposition order and remanded.

Issue	Father's Argument	DCFS's Argument	Held
Whether a court may order reunification services a parent cannot meaningfully comply with due to language barriers	Ordering English-only programs effectively doomed reunification; court should require Burmese services, interpreter, or limit obligations to on-demand testing	The court acted within discretion because father needed treatment for longstanding alcoholism; DCFS will assist in locating translated programs	Reversed: ordering programs known to be inaccessible due to language was an abuse of discretion
Whether the appeal was moot after later minute orders modifying plan and returning children home	Appeal not moot because subsequent orders changed, custody was later lost, and appellate relief (language-accessible services) remained relevant	Argued March 30, 2017 order and modification to on-demand testing mooted the appeal	Court declined to dismiss appeal as moot given later proceedings and ongoing relevance
Standard of review for dispositional reunification orders	N/A	N/A	Abuse of discretion governs disposition orders; substantial evidence governs review-hearing findings
Appropriate remedy when reunification plan is ordered but infeasible due to language	Requested specific remedial amendments (Burmese services or interpreter)	urged court could revisit at review hearings	Court reversed the ineffective portions but declined to mandate specific remedial terms, remanding for the dependency court to reconsider in light of opinion

In re D.C., 243 Cal.App.4th 41 (court reviews dispositional reunification orders for abuse of discretion)
In re A.E., 168 Cal.App.4th 1 (same standard for disposition review)
In re T.G., 188 Cal.App.4th 687 (substantial-evidence review for findings that reasonable services were provided)
Amanda H. v. Superior Court, 166 Cal.App.4th 1340 (same substantial-evidence principle)
In re Daniel B., 231 Cal.App.4th 663 (reunification plans must be tailored to family circumstances)
In re Dino E., 6 Cal.App.4th 1768 (effort must be made to provide suitable services despite difficulties)
Santosky v. Kramer, 455 U.S. 745 (parental rights termination implicates due process)
In re M.C., 199 Cal.App.4th 784 (mootness analysis in dependency appeals)
In re A.M., 217 Cal.App.4th 1067 (courts may decide technically moot dependency appeals raising issues capable of repetition yet evading review)
In re Natalie A., 243 Cal.App.4th 178 (discusses effect of diluted drug/alcohol tests)
In re T.W.-1, 9 Cal.App.5th 339 (remand discretion when intervening changes occur)