California Court of Appeal Mar 30, 2026 No. E086746Unpublished
Filed 3/30/26 In re J.C. CA4/2
NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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
FOURTH APPELLATE DISTRICT
DIVISION TWO
In re J.C., a Person Coming Under the Juvenile Court Law.
SAN BERNARDINO COUNTY CHILDREN AND FAMILY SERVICES, E086746
Plaintiff and Respondent, (Super.Ct.No. J305241)
v. OPINION
K.M.,
Defendant and Appellant.
APPEAL from the Superior Court of San Bernardino County. Steven A. Mapes,
Judge. Dismissed.
Caitlin E. Howard, under appointment by the Court of Appeal, for Defendant and
Appellant, K.M.
Laura Feingold, County Counsel, and Helena C. Rho, Deputy County Counsel, for
Plaintiff and Respondent.
1
I. INTRODUCTION
K.M. is the mother of J.C. J.C. was declared a dependent of the juvenile court
pursuant to Welfare and Institutions Code1 section 300, subdivision (b), shortly before he
turned 18 years old. In a dispositional hearing held after J.C. turned 18 years old, Mother
requested the juvenile court grant her reunification services for the first time pursuant to
section 361.6, which generally provides that the juvenile court “may order family
reunification services to continue for a nonminor dependent” and parents under specified
circumstances. (§ 361.6, subd. (a).) The juvenile court denied the request, and Mother
appeals from that order.
On appeal, Mother argues the juvenile court erred as a matter of law in its
interpretation of the authority granted under section 361.6. In response, San Bernardino
County Children and Family Services (CFS) contends that Mother lacks standing to
appeal and that the juvenile court did not err in its interpretation or application of the
statute. As we explain, discretionary services offered pursuant to section 361.6 are not
intended to further any legal or personal interest of a nonminor dependent’s parents.
Thus, we agree with CFS that Mother lacks standing, and we dismiss the appeal.
II. BACKGROUND
In July 2025, J.C.’s siblings reported that Mother and her husband had been
physically abusing J.C. J.C. was 17 years old at the time but suffered from serious
medical conditions that rendered him immobile and nonverbal.
1 Undesignated statutory references are to the Welfare and Institutions Code.
2
On July 15, 2025, CFS filed a dependency petition on behalf of J.C.
At the request of all parties, the juvenile court held an expedited jurisdictional hearing on
July 25, 2025 so that the juvenile court could take jurisdiction prior to J.C.’s 18th
birthday, rendering J.C. potentially eligible for extended foster care placement. Mother
admitted a jurisdictional allegation that she failed to provide proper medical and
nutritional care to J.C.; the juvenile court found true the admitted allegation; the juvenile
court dismissed all other allegations upon stipulation of the parties; and the juvenile court
declared J.C. a dependent of the juvenile court pursuant to section 300, subdivision (b).
In July 2025, J.C. turned 18 years old.
On August 21, 2025, the juvenile court held a dispositional hearing. Mother
requested the juvenile court order reunification services, purportedly under the authority
of section 361.6, subdivision (a). CFS opposed the request, arguing that reunification
services could not be ordered for the first time under section 361.6 after a dependent child
turns 18 years old. The juvenile court denied the request, observing that the statutory
language only provided for continuation of reunification services and did not provide
authority to order reunification services for the first time after a dependent child becomes
an adult.
Mother appeals from the dispositional order, challenging only the juvenile court’s
denial of reunification services.
3
III. DISCUSSION
CFS argues that we need not reach the substance of Mother’s arguments because
she lacks standing to challenge the juvenile court’s denial of reunification services on
appeal. We agree.
“In juvenile proceedings, only a party aggrieved by an order has standing to
appeal. [Citation.] ‘To be aggrieved, a party must have a legally cognizable interest that
is injuriously affected by the court’s decision.’ ” (In re B.S. (2021) 65 Cal.App.5th 888,
893.) “Whether a person has standing to raise a particular issue on appeal depends upon
whether the person’s rights were injuriously affected by the judgment or order appealed
from.” (In re A.K. (2017) 12 Cal.App.5th 492, 499.) “A person does not have standing
to urge errors on appeal that affect only the interests of others. [Citation.] Accordingly, a
parent is precluded from raising issues on appeal which do not affect his or her own
rights.” (Ibid.)
As relevant here, a parent’s individual interest in a dependency proceeding is the
right to “ ‘companionship, care, custody and management’ ” of the dependent child. (In
re K.C. (2011) 52 Cal.4th 231, 236.) Thus, the parent’s interest in reunification services
is “ ‘to facilitate the return of a dependent child to parental custody.’ ” (In re Jaden E.
(2014) 229 Cal.App.4th 1277, 1281.) Consistent with this understanding, California
courts have repeatedly declined to interpret dependency statutes in a manner that would
extend a right to reunification services where such services would not further any right to
custody. (In re Jodi B. (1991) 227 Cal.App.3d 1322, 1329 [A stepparent who has not
adopted a child “has no independent right to services designed to return the child to
4
parental custody.”]; In re J.B. (2025) 109 Cal.App.5th 133, 139 [A de facto parent has no
right to custody or reunification services.](Fourth Dist., Div. Two}; In re Zacharia D.
(1993) 6 Cal.4th 435, 451-452 [Biological fathers who do not obtain presumed father
status entitling them to custody do not qualify as parents entitled to receive reunification
services.]; R.S. v. Superior Court (2007) 154 Cal.App.4th 1262, 1271 [Reunification
services are not required for noncustodial parents who do not seek to regain custody of a
dependent child.].)
While a parent has a legally protected interest in pursuing custody of his or her
child while the child is a minor, the parent’s legal interest in the companionship, care,
and custody of his or her child is “eliminated entirely” when the child turns 18 years old.
(In re J.C. (2014) 222 Cal.App.4th 1489, 1493.) This is because “[a] person is
considered a minor under the laws of California until he or she turns 18, and after that is
considered to be an adult.” (In re Holly H. (2002) 104 Cal.App.4th 1324, 1334, fn. 4.)
“Although maturity is not achieved overnight, when one reaches majority[,] the law treats
the young adult as a responsible person entitled to make independent decisions in
conducting his or her affairs.” (Id. at p. 1336.)2 As a result, the dependency statutes
“d[o] not allow a parent to reunify with a dependent child who has turned 18 because a
2 This principle is recognized even where, as here, the adult may be severely disabled and in need of a future conservator. Conservatees “are adults, and the statute treats them as such even while investing a conservator and the court with certain powers to assist them where they are unable to assist themselves. . . . [¶] An adult conservatee’s disability does not put them in the legal position of a minor.” (Conservatorship of Navarrete (2020) 58 Cal.App.5th 1018, 1031.)
5
parent cannot have physical custody of an adult.” (In re K.L. (2012) 210 Cal.App.4th
632, 640.)
Thus, when J.C. turned 18 years old, he could not, as a matter of law, be returned
to Mother’s custody or “reunify” with her. By the time of her request, Mother had no
legally protected interest that would be furthered by reunification services, and she could
not be considered aggrieved by an order denying such services.
Mother concedes that her legally cognizable interest in J.C.’s care and
companionship was eliminated at the time J.C. turned 18 years old, but she argues that
section 361.6 “creates a legally cognizable interest in reunification services to confer
standing to appeal.” We are unpersuaded by this argument.
Whether a statute confers standing on a party is a matter of statutory interpretation,
which varies according to the intent of the Legislature in enacting the statute. (Guracar
v. Student Loan Solutions, LLC (2025) 111 Cal.App.5th 330, 342-343.) When
considering the interpretation of a statute, “ ‘ “ ‘ “our fundamental task . . . is to
determine the Legislature’s intent so as to effectuate the law’s purpose.” ’ ” ’ ” (People
v. Lewis (2021) 11 Cal.5th 952, 961.) “ ‘ “ ‘ “We begin by examining the statute’s
words, giving them a plain and commonsense meaning” ’ ” ’ ”; “ ‘ “we construe the
words in question ‘ “in context, keeping in mind the nature and obvious purpose of the
statute” ’ ” ’ ”; and we “ ‘ harmonize “the various parts of a statutory enactment . . . by
considering the particular clause or section in the context of the statutory framework as a
whole.” ’ ” (Ibid.)
6
It is true that section 361.6 provides authority for the juvenile court to order a
continuation of reunification services for a specified period of time after a dependent
child turns 18 years old. (§ 361.6., subd. (a).) However, the plain words of the statute
suggest that the continuation of services under section 361.6 was not intended to extend,
advance, or preserve any parental right. Under section 361.6, the continuation of
reunification services is authorized only if the juvenile court finds there is a “substantial
probability that the nonminor dependent will be able to safely reside in the home of the
parent . . . by the next review hearing.” (§ 361.6, subd. (a), italics added.) In contrast,
the continuation of reunification services for a minor dependent is authorized if the
juvenile court finds there is “a substantial probability that the child will be returned to the
physical custody of the child’s parent . . . within the extended time period.” (§ 361.5,
subd. (a)(3)(A).) “When different terms are used in parts of the same statutory scheme,
they are presumed to have different meanings.” (In re Austin P. (2004) 118 Cal.App.4th
1124, 1130.) The use of different terminology in this case clearly evidences a change in
legislative purpose. Notably, section 361.6 no longer references any custodial right of the
parent and makes no reference to the relational status of the parent and nonminor
dependent. Instead, the plain words of the statute suggest the purpose of continuing
services is to advance the nonminor dependent’s interest in securing a safe residence.
Our interpretation is consistent with the overall statutory purpose of nonminor
dependencies. The purpose of the nonminor dependency statutes is to “facilitate the
transition to adulthood of persons who entered the dependency system before age 18.”
(In re David B.(2017) 12 Cal.App.5th 633, 650, overruled in part by In re D.P. (2023)
7
14 Cal.5th 266, 283; In re Aaron S. (2015) 235 Cal.App.4th 507, 515-516; In re A.A.
(2016) 243 Cal.App.4th 765, 775.) Consistent with this purpose, the statutory scheme
requires the relevant county welfare agency to provide services to a nonminor dependent
that are intended to assist with the nonminor dependent’s transition to a living
arrangement outside of continued foster care, including assistance with obtaining health
insurance, securing housing, obtaining employment, and assistance with obtaining further
education and financial aid. (In re Holly H., supra, 104 Cal.App.4th 1324, 1331; § 391,
subd. (b).) Thus, interpreting section 361.6 as a statutory mechanism to facilitate the
nonminor dependent’s interest in securing a stable living arrangement is consistent with
the overall statutory scheme.
Further, we are called upon to interpret statutes in a manner that harmonizes the
statute with the statutory scheme as a whole. (In re Greg F. (2012) 55 Cal.4th 393, 407.)
As relevant here, “[t]he statutory scheme governing nonminor dependents . . . makes
clear that persons over age 18 are adults, even if they fall within the juvenile court’s
continuing dependency jurisdiction.” (In re David B., supra, 12 Cal.App.5th at p. 650;
§ 303, subd. (d)(1) [Nothing in the Welfare and Institutions Code shall be construed to
“otherwise abrogate any other rights that a person who has attained 18 years of age may
have as an adult under California law.”].) As an adult, a nonminor dependent is
permitted to initiate termination of dependency jurisdiction independent of the parent’s
cooperation or consent. (In re M.W. (2018) 26 Cal.App.5th 921, 928 [juvenile court
cannot continue jurisdiction where “ ‘the nonminor does not wish to remain subject to
dependency jurisdiction’ ”]; § 391, subd. (e)(1)(A).) And a hearing to terminate
8
jurisdiction over a nonminor dependent does not require the juvenile court to consider
any factors related to any parental interest. (Rules of Court, rule 5.555(d)(1) [listing
required findings].) It would be incongruous to conclude that section 361.6 confers a
parental right to reunification services where the rest of the statutory scheme clearly
provides that juvenile court jurisdiction may be terminated upon the request of the
nonminor alone without consideration of the impact such termination may have on a
parent receiving services.
Because we conclude that section 361.6 is not intended to advance any parental
interest or right, Mother cannot be considered aggrieved by a denial of reunification
services under that statute such that she has standing to appeal3. Accordingly, we
conclude that Mother lacks standing to pursue this appeal.
3 We also observe that, even if we assumed Mother had standing to appeal, she has not established entitlement to any relief on appeal. Even assuming section 361.6 authorized the trial court to grant Mother reunification services, any order of services under the statute is explicitly contingent on the agreement of the nonminor dependent. (§ 361.6, subd. (a).) The record shows that, at the time of the dispositional hearing, minor’s counsel declined to take a position regarding whether J.C. was in agreement with Mother’s request for services, specifically stating that J.C. “is not siding with Mother or County Counsel at this time”; did not “have enough information at this moment to go one way or the other”; and the guardian ad litem had not made a decision as to what would be in the best interests of J.C. regarding the services requested by Mother. Thus, the juvenile court could not have granted Mother reunification services under section 361.6, even if it believed the statute granted general authority to do so.
9
IV. DISPOSITION
The appeal is dismissed.
NOT TO BE PUBLISHED IN OFFICIAL REPORTS
FIELDS J. We concur:
RAMIREZ P. J.
McKINSTER J.
10
AI Brief
AI-generated · verify before citing
Holding. A parent lacks standing to appeal the denial of reunification services under Welfare and Institutions Code section 361.6 because the statute is intended to benefit the nonminor dependent's transition to adulthood rather than to further any parental interest in custody.
Issues
Does a parent have standing to appeal the denial of reunification services under Welfare and Institutions Code section 361.6 for a nonminor dependent?
Does section 361.6 confer a legally cognizable interest in reunification services upon a parent of a nonminor dependent?
Disposition. dismissed
Quotations verified verbatim against the opinion
“discretionary services offered pursuant to section 361.6 are not intended to further any legal or personal interest of a nonminor dependent’s parents. Thus, we agree with CFS that Mother lacks standing, and we dismiss the appeal.”
“Because we conclude that section 361.6 is not intended to advance any parental interest or right, Mother cannot be considered aggrieved by a denial of reunification services under that statute such that she has standing to appeal”