California Legal Brief

The Rule of In re K.L. is that DCFS satisfies its ICWA initial inquiry duty when it contacts parents and reasonably available extended family members, even if some extended family members remain unreachable despite good faith efforts, under circumstances where the agency attempted contact, obtained disconnected phone numbers, and family members declined to provide contact information without the missing person's consent.

The Rule of In re L.G. is that substantial evidence must support a juvenile court's finding that there are no reasonable means to protect a child without removal, and the Bureau must make reasonable efforts to prevent removal before a child can be taken from parental custody, under circumstances where a parent has mental health issues but the Bureau has not explored alternative interventions like family maintenance plans or evaluated available support persons.

The Rule of In re O.M. et al. is that uncontradicted evidence of parental inability to acknowledge or address a child's malnutrition compels dependency jurisdiction under section 300, subdivisions (b) and (j), under circumstances where the parent lacks insight into nutritional deficiencies despite hospitalization for malnutrition and cannot articulate a specific plan to prevent recurrence.

The Rule of Alternative Family Services is that foster family agencies (FFAs) have a duty to protect foster children from sexual abuse by foster parents where the FFA knew or should have known that the foster parent presented a risk of such abuse, under circumstances involving FFA negligence in screening and supervising foster parents who sexually abuse children.