In re E.V. CA2/2
When a juvenile court terminates its dependency jurisdiction over a child, it may issue an “order determining the custody of, or visitation with, the child,” and that order becomes part of an ongoing or new family law case and “continue[s] until modified or terminated by” the family court. (Welf. & Inst. Code, § 362.4.) However, such a so-called “exit order” cannot restrict the family court’s authority to modify or terminate the order. (In re Cole Y. (2015) 233 Cal.App.4th 1444, 1455-1457 (Cole Y.); In re John W. (1996) 41 Cal.App.4th 961, 972-973 (John W.).) When a juvenile court’s oral recitation of an exit order’s terms is internally inconsistent and could be construed as impermissibly restricting the family court, but the written exit order’s terms itself clearly do not, which is controlling? In this circumstance, we hold that the written order controls. And because the written order here is valid, we affirm.
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