Persons Coming Under the Juvenile Court Law. L. A. Cnty. Dep't of Children v. Brittney M. (In re Los), 224 Cal. Rptr. 3d 400

Parents Brittney and Joseph L. lived in Arizona with three children; maternal grandparents obtained custody of two older children in 2012 and later terminated the parents' rights for those children.
In March 2014 the parents brought seven-year-old Aiden to California; four months later (August 2014) law enforcement discovered drugs in the motel room where Aiden slept and Brittney was arrested; the LA County DCFS detained Aiden and placed him with a maternal great-aunt in California.
DCFS filed a dependency petition in California (Welf. & Inst. Code § 300); parents received reunification services, which were later terminated; parents had sporadic participation and later returned to Arizona.
In 2016 the juvenile court found Aiden adoptable and terminated parental rights (Aug 8, 2016); siblings and maternal grandparents (in Arizona) appealed, arguing California lacked UCCJEA jurisdiction because Arizona was the home state.
The appellate court held the juvenile court never addressed UCCJEA jurisdiction or contacted Arizona, and vacated the termination order, remanding for an evidentiary hearing to determine home-state or other UCCJEA jurisdiction and to comply with UCCJEA procedures.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether California had subject-matter jurisdiction under the UCCJEA (home-state or significant-connection basis)	Brittney: Arizona was Aiden's home state; California should have contacted Arizona and deferred	Department: California properly exercised jurisdiction and record supports jurisdiction	Vacated termination; remand for juvenile court to hold evidentiary hearing to determine home-state/temporary-absence and if California may exercise jurisdiction under §3421(a)(2); must contact Arizona if warranted
Whether exercise of temporary emergency jurisdiction allowed final custody orders without contacting home state	Brittney: Temporary emergency jurisdiction does not permit permanent orders when another state may be home state; court should have given Arizona opportunity to decide	Department: relied on California presence and emergency detention to proceed	Court: Temporary emergency jurisdiction alone insufficient; if another state may be home state court must contact that state and follow UCCJEA before entering permanent orders

In re Cristian, 224 Cal.App.4th 1088 (Cal. Ct. App.) (temporary emergency jurisdiction limited; further evidentiary hearing required before asserting permanent jurisdiction)
Ocegueda v. Perreira, 232 Cal.App.4th 1079 (Cal. Ct. App.) ("lived" = physical presence; avoids intent inquiry for home-state analysis)
In re Gino C., 224 Cal.App.4th 959 (Cal. Ct. App.) (temporary jurisdiction cannot be converted to permanent without complying with UCCJEA procedures)
Schneer v. Llaurado, 242 Cal.App.4th 1276 (Cal. Ct. App.) (jurisdictional fact findings reviewed for substantial evidence when facts are contested)
In re A.C., 13 Cal.App.5th 661 (Cal. Ct. App.) (UCCJEA is exclusive means to determine appropriate forum; appellate scope of review on jurisdictional facts)
In re M.M., 240 Cal.App.4th 703 (Cal. Ct. App.) (court must contact foreign/home state court and give it opportunity to exercise jurisdiction)
In re C.T., 100 Cal.App.4th 101 (Cal. Ct. App.) (temporary emergency jurisdiction limits and requirement to address UCCJEA jurisdiction before permanent orders)
In re Marriage of Nurie, 176 Cal.App.4th 478 (Cal. Ct. App.) (temporary absence analysis requires considering parents' intent and circumstances)
In re Nelson B., 215 Cal.App.4th 1121 (Cal. Ct. App.) (unauthorized removal and related considerations in home-state/temporary-absence analysis)