Santa Clara County Department of Family & Children's Services v. Aaron S.
235 Cal. App. 4th 507
| Cal. Ct. App. | 2015

Background

  • Aaron S. was a dependent minor who became a nonminor dependent at 18 under the Juvenile Court Law and Department of Family and Children’s Services supervision.
  • The juvenile court terminated dependency jurisdiction shortly before Aaron turned 19, finding he did not participate in his Transitional Independent Living Case Plan (TILP).
  • Aaron appealed, challenging the court’s participation finding and the absence of a 90‑day transition plan under §391(e)(2)(J).
  • The record shows Aaron previously struggled with school, employment, and compliance with services, including marijuana use and rule violations, though he graduated high school in 2013.
  • At the termination hearing, several months after Aaron’s failed attempts to enroll in college and secure employment, the court dismissed dependency but retained jurisdiction to hear future petitions.
  • The appellate court affirmed the termination, concluding Aaron did not meet the eligibility conditions of §11403(b) and thus was not participating in the TILP.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether Aaron participated in the TILP Aaron contends enrollment or program participation satisfied §11403(b)(2)-(3). Department argues Aaron did not enroll or engage sufficiently in employment-related activities. Yes, not participating; termination affirmed.
Whether Aaron’s attempt to enroll in postsecondary education satisfied §11403(b)(2) Aaron asserts his failed college enrollment should count as compliance. No enrollment occurred; mere attempts are insufficient. No; not enrolled, thus not meeting §11403(b)(2).
Whether Aaron’s employment efforts satisfied §11403(b)(3) Aaron claims contact with a recruiter and ILP participation show program designed to promote employment. Contacts were minimal and not part of an adequate plan; did not meet the criterion. No; insufficient program participation to satisfy §11403(b)(3).
Whether the Department’s failure to provide a 90-day transition plan requires reversal Aaron was entitled to a 90-day transition plan under §391(e)(2)(J). Aaron forfeited the issue by not objecting and by not meeting with staff. Harmless error; no reversal necessary.
Whether termination of jurisdiction was in Aaron’s best interests Best interests require ongoing services to support independence. Court may terminate where nonminor is not participating in the plan, regardless of best interests argument. Within discretion to terminate given lack of participation.

Key Cases Cited

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