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In re A.M. CA2/5
A juvenile court judge took jurisdiction over A.M., the then 12-month-old child of G.M. (Father) and H.M. (Mother), based on an uncontested allegation that the parents had an unresolved history of engaging in physical altercations in A.M.’s presence. The juvenile court found reasonable efforts had been made to avoid removing A.M. from his parents’ custody and entered a disposition order entrusting the Los Angeles County Department of Children and Family Services (DCFS) with A.M.’s care pending further proceedings. We are asked to decide whether Father is entitled to reversal based on his claim (not raised below) that the juvenile court failed to state facts supporting its reasonable efforts finding, and more broadly, that the order removing A.M. from his parents’ custody is not supported by substantial evidence.

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