Sonoma County Human Services Department v. J.H., 197 Cal. App. 4th 1542

A section 300 petition was filed October 10, 2008, alleging mother’s inability to care for minor due to substance abuse, lack of cooperation with hospital staff, and prior failure to reunify with siblings, with later amendments alleging harm to siblings and death-related issues.
The juvenile court sustained the second amended petition on November 19, 2008, and declared minor a dependent on March 3, 2009; ICWA applied based on mother’s tribal membership.
A dispositional order on March 3, 2009 bypassed reunification services under section 361.5(b)(4)(6)(10), finding mother caused the death of another child and that guardianship would be the permanent plan, with limited visitation.
Minor was placed with prospective guardians; guardianship was established, the proceedings were dismissed, and visitation with mother was set at least monthly.
Guardianship terminated November 24, 2009, triggering reinstatement of dependency; the court later scheduled permanency planning and considered new guardianship letters with potential reunification reconsideration.
May 2010 to July 2010 involved briefing and hearings on whether reunification services should be reconsidered before appointing a successor guardian; the court ultimately affirmed guardianship and limited visitation to twice yearly, two hours each.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether reunification services must be reconsidered before appointing a successor guardian	Mother contends 366.3(b)/(f) require reconsideration of reunification before guardianship changes.	Court rejected need for contested hearing, arguing guardianship remained unchanged and jurisdiction continued.	No reversible error; court properly denied reconsideration and affirmed guardianship.
Whether visitation was properly limited to twice yearly without a detriment finding	Mother argues more frequent visitation should be ordered absent a detriment finding.	Court followed permanency focus; visitation frequency reduced to protect the child’s stability.	Visitation reduction was appropriate and within the court’s discretion.

In re R.N., 178 Cal.App.4th 557 (Cal. Ct. App. 2009) (guardship changes trigger notice and reunification evaluation under §366.3)
In re Jessica C., 151 Cal.App.4th 474 (Cal. Ct. App. 2007) (guardianship modification may require reunification considerations)
In re Z.C., 178 Cal.App.4th 1271 (Cal. Ct. App. 2009) (parental rights protected; notice and opportunity to present evidence regarding reunification)
In re Kelly D., 82 Cal.App.4th 433 (Cal. Ct. App. 2000) (statutory interpretation using plain meaning and context to avoid absurd results)
In re Stephanie M., 7 Cal.4th 295 (Cal. 1994) (focus shifts to child’s permanency and best interests after bypassing reunification)