In re Cedric I. CA2/4
Appellant Elizabeth I. (mother) asserts that the juvenile court erred in the exit order (Welf. & Inst. Code, § 362.4 ) it issued upon termination of jurisdiction over mother’s teenage son, C. When the juvenile court terminates jurisdiction over a child, it may order counseling or other programs as part of its exit order. However, it may not condition future modification of that order upon the completion of counseling and other programs; such changes are within the province of the family court. (In re Cole Y. (2015) 233 Cal.App.4th 1444, 1456 (Cole Y.).) Mother asserts the juvenile court violated this rule by conditioning any future change in visitation on mother’s completion of drug tests and other programs. Respondent Los Angeles County Department of Children and Family Services (DCFS) disagrees, contending that the juvenile court’s recommendations that mother complete certain programs did not limit the family court’s power to make any future changes to the visitation order.
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