Los Angeles County Department of Children & Family Services v. Na.L., 236 Cal. App. 4th 1460

DFCS filed a 2013 Welfare and Institutions Code §300 petition alleging N.L. was endangered due to mother's drug use and false abuse allegations by mother against father.
In 2014 the juvenile court sustained the petition and declared N.L. a dependent, with father as custodial placement and mother’s monitored visitation.
Father sought a permanent restraining order in 2014; mother previously violated a 2013 order prohibiting contact with school and home.
At the October 2014 hearing the court issued a permanent restraining order that included N.L. as a protected person and allowed monitored visitation for mother.
Mother appeals challenging the inclusion of N.L. as a protected person, while the court and Department did not actively oppose the appeal.
The reviewing court ultimately remanded to modify the order to exclude N.L. as a protected person, while preserving a stay-away provision for mother when N.L. is with father.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether N.L. may be included as a protected person	Department contends safety concerns justify protection.	Mother argues no evidence shows N.L. safety would be jeopardized absent inclusion.	N.L. cannot be kept as a protected person; reverse to exclude N.L. while maintaining stay-away when N.L. is with father.

In re C.Q., 219 Cal.App.4th 355 (Cal. Ct. App. 2013) (protective orders need not rest on prior abuse; must protect child's safety)
In re Cassandra B., 125 Cal.App.4th 199 (Cal. Ct. App. 2004) (substantial evidence required; restraints may be limited to safety and visitation)
In re B.S., 172 Cal.App.4th 183 (Cal. Ct. App. 2009) (restraining orders can permit monitored visitation; focus on safety rather than past abuse alone)
In re Brittany K., 127 Cal.App.4th 1497 (Cal. Ct. App. 2005) (consideration of ongoing safety in determining order breadth)