In re K.M. CA2/1
The dependency proceedings giving rise to this appeal concern K.M., the daughter of M.P. (Mother) and T.M. (Father). When the juvenile court concluded its jurisdiction over K.M. and ended proceedings, it granted sole legal and physical custody to Father, with monitored visitation for Mother. The order to this effect addresses numerous details regarding Mother’s visitation rights, such as the frequency and duration of visits and the selection of a monitor. In the portion of the order addressing “reasons for no or supervised visitation” (capitalization omitted), the court noted that Mother “ha[d] not made substantial progress in the following court-ordered programs”: “[i]ndividual counseling” and “[o]ther . . . Mother must complete five . . . random or on demand drug tests and her Marijuana levels must be under 500 ng/ml.” At the hearing, the court described these provisions as a “rider” imposing testing and counseling requirements on Mother. Nowhere in the order, a
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