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In re Z.S. CA2/4
The Los Angeles County Department of Children and Family Services (DCFS) placed mother S.M.’s daughter, Z., in protective custody shortly after her birth. DCFS subsequently filed a petition alleging Z. was at substantial risk of suffering serious physical harm or illness due to mother’s substance abuse and mental and emotional problems. (Welf. & Inst. Code, § 300, subd. (b)(1).) The juvenile court sustained the petition, removed Z. from mother, and placed her in foster care. Mother appealed. While her appeal was pending, the juvenile court ordered Z. released to mother and terminated jurisdiction.

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