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7 California opinions name it 1 courts 2016–2025 6 in the last five years
The cases below were cited by California courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
In Re Lucero L.green2 sentences2025Section 355, subdivision (a) provides that for purposes of a jurisdictional hearing, “[a]ny legally admissible evidence that is relevant to the circumstances or acts that are alleged to bring the minor within the jurisdiction of the juvenile court is admissible and may be received in evidence.” A social study and the hearsay evidence contained in it are admissible and constitute competent evidence on which a finding of jurisdiction pursuant to section 300 may be based, to the extent allowed by section 355, subdivisions (c) and (d). (§ 355, subd. (b).) “If a party to the jurisdictional hearing 2022This failure to object is fatal to his claim that we should reverse because the evidence was hearsay and “[m]ere uncorroborated hearsay does not constitute substantial evidence.” (Kevin R. v. Superior Court (2010) 191 Cal.App.4th 676, 689 , citing In re Lucero L. (2000) 22 Cal.4th 1227, 1243 .) At the jurisdictional hearing, the “social study prepared by the petitioning agency, and hearsay evidence contained in it, is admissible and constitutes competent evidence upon which a finding of jurisdiction pursuant to Section 300 may be based.” (§ 355, subd. (b), italics added.) Only if “a party to t | 1 | 3 |
In Re Malinda S.red1 sentence2023However, the hearsay statement of a minor under 12 years of age shall not be admissible if the objecting party establishes that the statement is unreliable because it was the product of fraud, deceit, or undue influence.” (§ 355, subd. (c)(1)(B)), as added by Stats.1996, ch. 36, § 1; see also Cal. Rules of Court, rule 5.684(b).) In Lucero L., supra, 22 Cal.4th 1227 , the court held, “consistent with the language of section 355, subdivision (b), that the hearsay statements contained in social studies should be admissible even if they do not meet the requirements of the child dependency exceptio | 1 | 1 |
Sacramento County Welfare Department v. Lawrence Z.green1 sentence2022(See § 355, subd. (c)(1); In re E.B. (2010) 184 Cal.App.4th 568 , 577, disapproved on other grounds in Conservatorship of O.B. (2020) 9 Cal.5th 989 [father failed to object to the hearsay in the social workers report, so juvenile court was entitled to rely on it]); In re Tracy Z. (1987) 8 195 Cal.App.3d 107, 113 [“If there is any substantial evidence, contradicted or uncontradicted, which will support the judgment, we must affirm. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in California. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
In Re BD
green
2 sentences2025(In re B.D. (2007) 156 Cal.App.4th 975, 983-984 .) “Corroborating evidence is ‘[e]vidence supplementary to that already given and tending to strengthen or confirm it. 2022(In re B.D. (2007) 156 Cal.App.4th 975, 984 .) “Corroborating evidence is ‘[e]vidence supplementary to that already given and tending to strengthen or confirm it. [It is] [a]dditional evidence of a different character to the same point.’ [Citation.] In this context, corroborating evidence is that which supports a logical and reasonable inference that the act described in the hearsay statement occurred.” (Ibid.) “[C]orroborative evidence, whether direct or circumstantial, (1) is sufficient if it tends to connect the allegedly offending parent with the alleged negligent act even though it is sli | 4 | 2016–2025 |
Los Angeles County Department of Children and Family Services v. Sandra D.
green
2 sentences2022(In re B.D. (2007) 156 Cal.App.4th 975, 984 .) “Corroborating evidence is ‘[e]vidence supplementary to that already given and tending to strengthen or confirm it. [It is] [a]dditional evidence of a different character to the same point.’ [Citation.] In this context, corroborating evidence is that which supports a logical and reasonable inference that the act described in the hearsay statement occurred.” (Ibid.) “[C]orroborative evidence, whether direct or circumstantial, (1) is sufficient if it tends to connect the allegedly offending parent with the alleged negligent act even though it is sli 2016(In re R.R. (2010) 187 Cal.App.4th 1264, 1280 , citing In re B.D. (2007) 156 Cal.App.4th 975 , 983–984.) “[W]ith respect to dependency jurisdictional findings, corroborative evidence, whether direct or circumstantial, (1) is sufficient if it tends to connect the allegedly offending parent with the alleged negligent act even though it is slight and ‘ “entitled, when standing by itself, to but little consideration [citations], nor does it need to establish the precise facts” ’ in the hearsay statements; (2) is sufficient if it tends to connect the allegedly offending parent with the alleged negl | 2 | 2016–2022 |
L. A. Cnty. Dep't of Children & Family Servs. v. Lisa E. (In Re R.T.)
green
1 sentence2025(R.T., supra, 3 Cal.5th at p. 633 .) As for risk to F.M.’s daughters, there was evidence R.G. was abused in the presence of one of the daughters, and at the time of the jurisdictional hearing, F.M.’s oldest daughter was five years old, an age similar to R.G.’s age when the abuse began. 12 Section 355, subdivision (b) provides that hearsay evidence contained in an agency’s social study “is admissible and constitutes competent evidence upon which a finding of jurisdiction pursuant to Section 300 may be based, to the extent allowed by subdivisions (c) and (d).” Section 355, subdivision (c)(1) mak | 1 | 2025–2025 |
In Re EB
green
1 sentence2022(See § 355, subd. (c)(1); In re E.B. (2010) 184 Cal.App.4th 568 , 577, disapproved on other grounds in Conservatorship of O.B. (2020) 9 Cal.5th 989 [father failed to object to the hearsay in the social workers report, so juvenile court was entitled to rely on it]); In re Tracy Z. (1987) 8 195 Cal.App.3d 107, 113 [“If there is any substantial evidence, contradicted or uncontradicted, which will support the judgment, we must affirm. | 1 | 2022–2022 |
Kevin R. v. Superior Court
green
1 sentence2022This failure to object is fatal to his claim that we should reverse because the evidence was hearsay and “[m]ere uncorroborated hearsay does not constitute substantial evidence.” (Kevin R. v. Superior Court (2010) 191 Cal.App.4th 676, 689 , citing In re Lucero L. (2000) 22 Cal.4th 1227, 1243 .) At the jurisdictional hearing, the “social study prepared by the petitioning agency, and hearsay evidence contained in it, is admissible and constitutes competent evidence upon which a finding of jurisdiction pursuant to Section 300 may be based.” (§ 355, subd. (b), italics added.) Only if “a party to t | 1 | 2022–2022 |
In Re RR
green
1 sentence2016(In re R.R. (2010) 187 Cal.App.4th 1264, 1280 , citing In re B.D. (2007) 156 Cal.App.4th 975 , 983–984.) “[W]ith respect to dependency jurisdictional findings, corroborative evidence, whether direct or circumstantial, (1) is sufficient if it tends to connect the allegedly offending parent with the alleged negligent act even though it is slight and ‘ “entitled, when standing by itself, to but little consideration [citations], nor does it need to establish the precise facts” ’ in the hearsay statements; (2) is sufficient if it tends to connect the allegedly offending parent with the alleged negl | 1 | 2016–2016 |