Los Angeles County Department of Children & Family Services v. William C.
54 Cal. 4th 610
| Cal. | 2012Background
- Valerie, Ethan, and Jesus were in the care of William C. and Kimberly G.; Valerie died after being unrestrained in a vehicle driven by William, contributing to fatal crash proceedings.
- Department filed a dependency petition for Ethan and Jesus alleging risk due to domestic violence, Kimberly's cognitive impairments, and William's alleged failure to securely restrain Valerie.
- Jurisdictional/dispositional hearing sustained certain § 300 allegations (f and j related to Valerie's death) and others related to domestic violence and Kimberly's impairments, leading to adjudication as dependents with reunification services.
- Court held that § 300(f) permits dependency based on a parent causing the death of another child through abuse or neglect, potentially based on ordinary negligence, not requiring criminal negligence.
- William appealed claiming § 300(f) requires criminal negligence and that there was no current risk to surviving children; court affirmed, holding no such limitations and applying ordinary negligence as a valid basis.
- Court applied a 'substantial contributing cause' standard to causation, determining William's failure to use a child safety seat was a substantial factor in Valerie's death.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does § 300(f) require criminal negligence to support dependency? | William: requires criminal negligence. | Court: § 300(f) allows ordinary neglect as cause. | No; § 300(f) may be based on ordinary neglect. |
| Does § 300(f) require discrete evidence of current risk to living children? | William: must show current risk to Ethan/Jesus. | Court of Appeal majority: need not show current risk beyond the fatality. | No separate current-risk finding required. |
| What is the meaning of 'caused' in § 300(f)? | William: death must be caused by culpable conduct; not mere ordinary negligence. | Court: 'caused' uses ordinary causation concepts; not limited to criminal negligence. | Caused includes substantial-factor causation; ordinary negligence can suffice. |
| Can ordinary-negligence causing another child’s death support dependency under § 300(f)? | William: only aggravated/culpable conduct justifies § 300(f). | Court: ordinary negligence can support dependency when it results in a child’s death. | Yes; ordinary negligence can satisfy § 300(f) in appropriate cases. |
Key Cases Cited
- Stark v. Superior Court, 52 Cal.4th 368 (Cal. 2011) (defines criminal negligence broadly; supports non-criminal standard in § 300(f))
- In re A.M., 187 Cal.App.4th 1380 (Cal. App. 2d Dist. 2010) (relevance to causation and § 300/f interpretations)
- In re Alexis M., 54 Cal.App.4th 848 (Cal. App. 2d Dist. 1997) (reunification considerations post-lethal abuse/neglect findings)
- In re Ethan N., 122 Cal.App.4th 55 (Cal. App. 2d Dist. 2004) (reunification and aggravated circumstances guidance in § 361.5)
- In re J.N., 181 Cal.App.4th 1010 (Cal. App. 2d Dist. 2010) (current risk requirement discussion for § 300(b) not controlling § 300(f))
- People v. Sims, 32 Cal.3d 468 (Cal. 1982) (collateral estoppel and related causation considerations)
- Teitelbaum Furs, Inc. v. Dominion Ins. Co., Ltd., 58 Cal.2d 601 (Cal. 1962) (illustrative of general causation principles)
- In re J.N., 2010 Cal.App.4th 1010 (Cal. App. 2d Dist. 2010) (discussion of risk standards in dependency cases)
- In re J.K., 174 Cal.App.4th 1426 (Cal. App. 2d Dist. 2009) (current risk requirements for § 300(b))