D.N. v. Superior Court CA1/4

── D.N. v. Superior Court CA1/4 ── Court: California Court of Appeal Date: May 28, 2026 Category: General Filed 5/28/26 D.N. v. Superior Court CA1/4 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115. IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA FIRST APPELLATE DISTRICT DIVISION FOUR D.N., Petitioner, v. THE SUPERIOR COURT OF A175870 SAN FRANCISCO COUNTY, (San Francisco City & Respondent; County Super. Ct. No. SAN FRANCISCO HUMAN JD24-3018) SERVICES AGENCY, Real Party in Interest. D.N. (mother) petitions for an extraordinary writ (Cal. Rules of Court, rule 8.452) in the dependency case of her child, M.-J.R.C. (minor). Mother challenges the juvenile court’s decision at the 18-month review hearing to terminate reunification services and set a hearing under Welfare and Institutions Code1 section 366.26, arguing that substantial evidence does not support the trial court’s determination that the San Francisco Human Services Agency (agency) offered her 1 Statutory citations are to the Welfare and Institutions Code. 1 reasonable reunification services. Mother also requests a stay of the section 366.26 hearing. We find no error in the juvenile court’s decision and will therefore deny the petition and stay request. As the parties are already familiar with the factual and procedural history of the case and this opinion does not warrant publication, we need not recite the full history of the dependency proceedings here. (People v. Garcia (2002) 97 Cal.App.4th 847, 851.) At an 18-month review hearing in a dependency case, the court “shall determine by clear and convincing evidence whether reasonable services have been offered or provided to the parent or legal guardian.” (§ 366.22, subd. (a)(3).) With an exception not relevant here, if the court does not return the child to the parent and it “finds that reasonable services have not been provided, . . . the court shall extend reunification services for an additional six months” (§ 366.22, subd. (b)(2)(A)) unless it finds, based on evidence from a mental health professional, that doing so would be detrimental to the child (id., subd. (b)(2)(B)). We review a trial court’s reasonable services finding to determine whether there is substantial evidence from which the juvenile court could have made the finding by clear and convincing evidence. (B.D. v. Superior Court (2025) 110 Cal.App.5th 1132, 1150, 1155.) “ ‘Reunification services must be “designed to eliminate those conditions that led to the court’s finding that the child is a person described by Section 300.” ’ [Citation.] ‘The standard is not whether the services provided 2 were the best that might be provided in an ideal world, but whether the services were reasonable under the circumstances.’ [Citation.] Thus, while ‘services need not be perfect,’ they ‘should be tailored to the specific needs of the particular family.’ [Citation.] In this regard, ‘ “the record should show that the supervising agency identified the problems leading to the loss of custody, offered services designed to remedy those problems, maintained reasonable contact with the parents during the course of the service plan, and made reasonable efforts to assist the parents in areas where compliance proved difficult (such as helping to provide transportation and offering more intensive rehabilitation services where ot