San Mateo County Human Services Agency v. Kia E., 229 Cal. App. 4th 1277

Kia E. (mother) sought relief from an order terminating her discretionary reunification services under §361.2(b)(3).
The child, Jaden, was removed and placed with a previously noncustodial father at disposition under §361.2(b)(3).
The juvenile court terminated mother’s reunification services while the child remained in placement with the father.
The parties disagreed on whether a reasonable services finding was required at review hearings monitoring the placement.
The appellate court held that such a reasonable services finding is not required at periodic reviews when custody remains with a parent under §361.2(b)(3).
The court affirmed the termination of mother’s §361.2 services, finding no abuse of discretion given the best interests of the child.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a reasonable services finding is required at review hearings for §361.2(b)(3) placements	Kia asserts services were unreasonable and the finding was required.	Agency contends no such finding is required at these reviews.	No, not required.
Whether termination of §361.2(b)(3) services was an abuse of discretion	Mother argues continued services were warranted given potential for reunification.	Agency contends termination was appropriate to focus on the child’s best interests with the father.	No abuse; termination upheld.
What standards apply to custody determinations in §361.2 placements	N/A (court-focused on whether appropriate services were provided).	Best interests of the child guide custody determinations at §366 reviews.	Best interests govern custody; review should assess ongoing necessity of supervision.

In re Jodi B., 227 Cal.App.3d 1322 (1991) (purpose of reunification and timing of services)
In re Baby Boy H., 63 Cal.App.4th 470 (1998) (goal of reunification efforts to preserve family)
Erika W., 28 Cal.App.4th 470 (1994) (distinction between 361.5 reunification obligations and 361.2 noncustodial placements)
In re Nicholas H., 112 Cal.App.4th 251 (2003) (review procedures when placed with a previously noncustodial parent; focus on best interests)
Janee W., 140 Cal.App.4th 1444 (2006) (reasonableness of services to a previously custodial parent need not block termination under §361.2)
In re A.C., 169 Cal.App.4th 636 (2008) (361.2 vs 361.5 interplay; 361.5 timelines do not apply when not removing custody from both parents)
In re T.W., 214 Cal.App.4th 1154 (2013) (timelines for reunification and non-applicability of 361.5 clock in §361.2 context)
In re N.M., 108 Cal.App.4th 845 (2003) (timelines for reunification under 361.5; distinctions from family maintenance)
In re Joel T., 70 Cal.App.4th 263 (1999) (family maintenance vs reunification services; impact on subsequent removals)
In re A.J., 214 Cal.App.4th 525 (2013) (appellate review standard—correct ruling affirmed on any ground)