six-month review hearing in California

2025The juvenile court is not authorized to set a section 366.26 hearing at the six-month review hearing unless the parent’s failure to make substantive progress in court-ordered treatment is shown by “clear and convincing evidence.” (§ 366.21, subd. (e)(3); M.V., supra, 167 Cal.App.4th at pp. 175–176.) By contrast, the statute does not impose this heightened standard of proof in the parent’s favor at the later review stages when continued services have become disfavored.

2024(M.V. v. Superior Court (2008) 167 Cal.App.4th 166, 176 .) If, however, “the court finds there is a substantial probability that the child … may be returned to [his or her] parent or legal guardian within [six] months or that reasonable services have not been provided …, the court shall continue the case to the 12-month permanency [review] hearing.” (§ 366.21, subd. (e)(3).) We review for substantial evidence a juvenile court’s factual findings supporting an order terminating reunification services at a six-month review hearing.

2024“For a child under three years of age at the time of removal, as [D.S.L.] was, reunification services are presumptively limited to six months.” (Tonya M. v. Superior Court, supra, 42 Cal.4th 836, 843 ; see also § 361.5, subd. (a)(1)(B).) Given the delays in holding the six-month review hearing, Father was provided with nearly 18 months to demonstrate a sufficient capacity to provide adequate care for D.S.L.

2024Statutory Framework For a parent of a child under three years of age at the time of removal, the statutory scheme for providing reunification services establishes “three distinct periods and three corresponding distinct escalating standards . . . .” (Tonya M. v. Superior Court (2007) 42 Cal.4th 836, 845 .) During the first period, from the jurisdictional hearing to the six-month review hearing, services are “afforded essentially as a matter of right,” subject to certain statutory exceptions not relevant here.

2025In such cases, the juvenile court may, at the six-month review hearing, schedule a permanency planning hearing under section 366.26. (§ 366.21, subd. (e)(3).) “If, however, the court finds . . . that reasonable services have not been provided, . . . the court shall continue the case to the 12-month permanency hearing.” (Ibid.) “[T]he court shall determine by clear and convincing evidence whether reasonable services that were designed to aid the parent or legal guardian in overcoming the problems that led to the initial removal and the continued custody of the child have been provided or offere

2022If a child is not returned to his or her parent at the six-month review hearing, the juvenile court “shall determine whether reasonable services that were designed to aid the parent … in overcoming the problems that led to the initial removal and continued custody of the child have been provided or offered to the parent.” (§ 366.21, subd. (e)(8); § 366, subd. (a)(1)(B) [at each status review hearing the court shall determine “[t]he extent of the agency’s compliance with the case plan in making reasonable efforts … to return the child to a safe home”].) “ ‘A finding that reasonable reunificatio

2022The proposed amendments do not substantively alter the subsections discussed herein. 17 Jesse W. (2007) 157 Cal.App.4th 49 , 61; see also In re Derrick S. (2007) 156 Cal.App.4th 436, 450 [reunification is “standard topic at” six-month review hearings].) At a six-month review hearing, when a child is under three at the time of his or her initial removal, the court has the discretion under certain circumstances to set a 366.26 hearing and to terminate reunification services. (§ 366.21, subd. (e)(3).) 5 The juvenile court at the six-month review must make “two distinct determinations” in ascertai

2021Under these circumstances, the juvenile court retains the discretion to terminate the offer of services to one parent.” (In re Jesse W. (2007) 157 Cal.App.4th 49, 65 (Jesse W.); see also id. at p. 58 [“[A]t a six-month review hearing, the juvenile court retains the discretion to terminate the offer of services to one parent even if the other parent is receiving services and no section 366.26 hearing is set.”]; § 366.21, subd. (e)(8) [“If the child is not returned to his or her parent or legal guardian, . . . . [t]he court shall order that [the] services [offered to the parent] be initiated, co

2025General Legal Principles After the juvenile court finds jurisdiction under section 300, it may remove a child from a parent pursuant to section 361 at a dispositional hearing only if it finds by clear and convincing evidence “[t]here is or would 12 be a substantial danger to the physical health, safety, protection, or physical or emotional well-being of the minor if the minor were returned home, and there are no reasonable means by which the minor’s physical health can be protected without removing the minor from the minor’s parents.” (§ 361, subd. (c)(1); see Cynthia D. v. Superior Court (199

2023When the juvenile court has found jurisdiction under section 300, it may remove a child from a parent pursuant to section 361 at a dispositional hearing only if it finds by clear and convincing evidence “[t]here is or would be a substantial danger to the physical health, safety, protection, or physical or emotional well-being of the minor if the minor were returned home, and there are no reasonable means by which the minor’s physical health can be protected without removing the minor from the minor’s parents.” (§ 361, subd. (c)(1); see Cynthia D. v. Superior Court (1993) 5 Cal.4th 242 , 248−24

2021Under these circumstances, the juvenile court retains the discretion to terminate the offer of services to one parent.” (In re Jesse W. (2007) 157 Cal.App.4th 49, 65 (Jesse W.); see also id. at p. 58 [“[A]t a six-month review hearing, the juvenile court retains the discretion to terminate the offer of services to one parent even if the other parent is receiving services and no section 366.26 hearing is set.”]; § 366.21, subd. (e)(8) [“If the child is not returned to his or her parent or legal guardian, . . . . [t]he court shall order that [the] services [offered to the parent] be initiated, co

2016(In re Alanna A. (2005) 135 Cal.App.4th 555, 565-566 ; In re Jesse W. (2007) 157 Cal.App.4th 49, 59-60 .) 8 In determining whether to continue reunification services at the six-month review hearing, the juvenile court considers only the probable developments in the period for which services can be ordered, i.e., if at most four months remain until the 12-month review hearing, then the court should only consider what the impact of those four months of services would be on the parent and child.

2023(See M.V., supra, 167 Cal.App.4th at p. 183 ; S.T. v. Superior Court, supra, 177 Cal.App.4th at p. 1016 .) Here, it is not reasonably probable mother could have obtained a more favorable result had the court at the six-month review hearing explicitly considered whether there was a “strong likelihood of a possibility of return” within another six months (M.V., supra, 167 Cal.App.4th at p. 181 , italics omitted).

2022(M.V., supra, at p. 176; see also S.T. v. Superior Court (2009) 177 Cal.App.4th 1009, 1015-1016 (S.T.).) If the court at the six-month review hearing exercises its discretion to set a 366.26 hearing within 120 days, it must terminate reunification services at that time. (§ 366.21, subd. (h).) But the juvenile court may not order a 366.26 hearing “unless there is clear and convincing evidence that reasonable services have been provided or offered to the parent or legal guardian.” (§ 366.21, subd. (g)(1)(C)(ii).) B.

2022The proposed amendments do not substantively alter the subsections discussed herein. 17 Jesse W. (2007) 157 Cal.App.4th 49 , 61; see also In re Derrick S. (2007) 156 Cal.App.4th 436, 450 [reunification is “standard topic at” six-month review hearings].) At a six-month review hearing, when a child is under three at the time of his or her initial removal, the court has the discretion under certain circumstances to set a 366.26 hearing and to terminate reunification services. (§ 366.21, subd. (e)(3).) 5 The juvenile court at the six-month review must make “two distinct determinations” in ascertai

2014The essential purpose of the hearing is for the court “to provide stable, permanent homes for these children.” (§ 366.26, subd. (b); see In re Jose V. (1996) 50 Cal.App.4th 1792 , 1797.) Prior to the permanency hearing, there are periodic status reviews as ordered by the court, but not less frequently than every six months. (§ 366, subd. (a)(1).) “At the review hearing held six months after the initial dispositional hearing [the six-month review hearing], the court shall order the return of the child to the physical custody of his 26 or her parent or legal guardian unless the court finds, by a

2022At the six-month review hearing, the juvenile court must determine whether the Department has made reasonable efforts to provide reunification services to mother and the extent of her progress toward alleviating or mitigating the causes that led to the minor’s detention. (§§ 366, subd. (a)(1)(B), 366.21, subd. (e)(8) [six-month review-reasonable services].) The Department “must make a good faith effort to provide reasonable services responsive to the unique needs of each family, and the plan must be . . . ‘“‘designed to eliminate those conditions which led to the juvenile court’s jurisdictiona

2021DISCUSSION Reasonable services At the six-month review hearing, the court must determine whether the Department has made reasonable efforts to provide reunification services to father and the extent of his progress toward alleviating or mitigating the causes that led to the minor’s detention. (§§ 366, subd. (a)(1)(B), 366.21, subd. (e)(8) [six-month review-reasonable services].) The Department “must make a good faith effort to provide reasonable services responsive to the unique needs of each family, and the plan must be . . . ‘“‘designed to eliminate those conditions which led to the juvenile

2021Before the 12-month review hearing, the Agency relied on the parents’ overall 2 “In accord with the usual rules on appeal, we state the facts in the manner most favorable to the dependency court’s order.” (In re Janee W. (2006) 140 Cal.App.4th 1444, 1448, fn. 1 .) 3 progress to recommend that the children remain dependents of the court, that they be placed with parents, and that six months of family maintenance services be provided.

2015“Even though section 361.2, by its terms, applies when the court first takes jurisdiction of a child, its procedures can be invoked at the six-month and 12-month review hearings, as occurred here.” (In re Janee W. (2006) 140 Cal.App.4th 1444, 1451 .) In fact, the California Rules of Court specifically contemplate the application of section 361.2 procedures when the child is placed with the previously noncustodial parent at subsequent review hearings, and expressly provide for placement with the noncustodial parent at the six-month review hearing.

2025Substantial Evidence Supports the Court’s Reasonable Services Finding At the six-month review hearing, the juvenile court “shall order the return of the child to the physical custody of their parent or legal guardian unless the court finds, by a preponderance of the evidence, that the return of the child to their parent or legal guardian would create a substantial risk of detriment to the safety, protection, or physical or emotional well- being of the child.” (§ 366.21, subd. (e)(1).) “If the child is not returned to their parent or legal guardian, the court shall determine by clear and convin

2025“When it appears at the six-month review hearing that a parent has not been afforded reasonable reunification services, the remedy is to extend the reunification period, and order continued services.” (In re Alvin R. (2003) 108 Cal.App.4th 962 , 973–974.) Section 366.21, subdivision (e)(3) provides the juvenile “court shall continue the case to the 12-month permanency hearing” if it finds at the six-month review hearing reasonable services were not provided.

2025In T.G., the appellate court reasoned that “a parent or child can [be] aggrieved by a reasonable services finding at the time of the six- month review hearing if it is not supported by substantial evidence” because “[s]uch a finding can put the interests of parents and children in reunification at a significant procedural disadvantage.” (T.G., supra, 188 Cal.App.4th at p. 695 .) In Melinda K., the court recognized that a reasonable services finding “may have negative consequences at subsequent hearings.” (Melinda K., supra, 116 Cal.App.4th at p. 1150 .) We concur and conclude that an erroneous

2025However, several appellate courts have reviewed the finding on reasonable services despite the grant of additional reunification services based on the possibility of negative consequences at subsequent hearings. 15 In Melinda K. v. Superior Court (2004) 116 Cal.App.4th 1147 (Melinda K.), the mother had been granted six months of reunification services, and at the six-month review hearing, the children’s services department reported she had been consistent in visitation and completed her classes.

2025In T.G., the appellate court reasoned that “a parent or child can [be] aggrieved by a reasonable services finding at the time of the six- month review hearing if it is not supported by substantial evidence” because “[s]uch a finding can put the interests of parents and children in reunification at a significant procedural disadvantage.” (T.G., supra, 188 Cal.App.4th at p. 695 .) In Melinda K., the court recognized that a reasonable services finding “may have negative consequences at subsequent hearings.” (Melinda K., supra, 116 Cal.App.4th at p. 1150 .) We concur and conclude that an erroneous

2025In T.G., the appellate court reasoned that “a parent or child can [be] aggrieved by a reasonable services finding at the time of the six- month review hearing if it is not supported by substantial evidence” because “[s]uch a finding can put the interests of parents and children in reunification at a significant procedural disadvantage.” (T.G., supra, 188 Cal.App.4th at p. 695 .) In Melinda K., the court recognized that a reasonable services finding “may have negative consequences at subsequent hearings.” (Melinda K., supra, 116 Cal.App.4th at p. 1150 .) We concur and conclude that an erroneous

2023Applicable Law and Standard of Review After a child is removed from parental custody, “the juvenile court must review the case at least once every six months.” (Cynthia D. v. Superior Court (1993) 5 Cal.4th 242, 249 .) At the six-month review hearing, “the court shall order the 16 return of the child to the physical custody of their parent or legal guardian unless the court finds, by a preponderance of the evidence, that the return of the child to their parent or legal guardian would create a substantial risk of detriment to the safety, protection, or physical or emotional well-being of the ch

2023When the juvenile court has found jurisdiction under section 300, it may remove a child from a parent pursuant to section 361 at a dispositional hearing only if it finds by clear and convincing evidence “[t]here is or would be a substantial danger to the physical health, safety, protection, or physical or emotional well-being of the minor if the minor were returned home, and there are no reasonable means by which the minor’s physical health can be protected without removing the minor from the minor’s parents.” (§ 361, subd. (c)(1); see Cynthia D. v. Superior Court (1993) 5 Cal.4th 242 , 248−24

2022If a child is not returned to his or her parent at the six-month review hearing, the juvenile court “shall determine whether reasonable services that were designed to aid the parent … in overcoming the problems that led to the initial removal and continued custody of the child have been provided or offered to the parent.” (§ 366.21, subd. (e)(8); § 366, subd. (a)(1)(B) [at each status review hearing the court shall determine “[t]he extent of the agency’s compliance with the case plan in making reasonable efforts … to return the child to a safe home”].) “ ‘A finding that reasonable reunificatio

2021(Amanda H. v. Superior Court (2008) 166 Cal.App.4th 1340, 1345 .) Because a finding of reasonable services must be made by clear and convincing evidence in the trial court, “ ‘[w]e review the record in the light most favorable to the trial court’s order to determine whether there is substantial evidence from which a reasonable trier of fact could make the necessary findings based on the clear and convincing evidence standard.’ ” (T.J. v. Superior Court (2018) 21 Cal.App.5th 1229 , 1238–1240.) When a child under the age of three is removed from a parent, family reunification services are initia

2024(Michael G. v. Superior Court (2023) 14 Cal.5th 609 , 624 (Michael G.); § 361.5, subd. (a).) This same complement of mandatory, time-limited reunification services applies where, as here, a previously noncustodial parent gains custody of a child but subsequently the child is removed.6 (See In re Jaden E. (2014) 229 Cal.App.4th 1277, 1281 ; In re T.W. (2013) 214 Cal.App.4th 1154, 1169-1170 (T.W.).) At the six-month review hearing for a child not placed with any parent, “[t]here is a statutory presumption the child will be returned to parental custody unless the court finds the child’s return wo

2016Six-month Review Hearing “If a child has been declared a dependent of the juvenile court and placed under court supervision, the status of the child must be reviewed every six months.” (Bridget A. v. Superior Court, supra, 148 Cal.App.4th at p. 303 .) The applicable standards at the six- month review hearing differ depending on the child’s placement.

2024(Sara M. v. Superior Court (2005) 36 Cal.4th 998, 1018 [appeal from the most recent order in a dependency matter may not challenge earlier orders for which the time to file an appeal has passed].) Mother also makes several assertions that appear to have occurred after the six- month review hearing, including that father “has been asked to leave the country,” and that he had mentioned to the maternal grandmother “he has new financial burdens since the baby.” These contentions are not proper for our review because they allude to 4. evidence not before the juvenile court and are outside the recor

2023Just as an unappealed disposition or postdisposition order that is final and binding may not be attacked on an appeal from a later appealable order (Sara M. v. Superior Court (2005) 36 Cal.4th 998, 1018 , citing In re Jesse W. (2001) 93 Cal.App.4th 349, 355 ), an appeal from a six-month review hearing may not serve as a basis to vacate or modify an unappealed order or judgment made at a later hearing.

2016DISCUSSION A. Applicable Legal Standards Due to the special needs of infants and toddlers for permanency and stability, court-ordered services for children who are younger than three years old, such as R.W., are limited by statute to “six months from the dispositional hearing … but no longer than 12 months from the date the child entered foster care. . . .” (§ 361.5, subd. (a)(1)(B); see also Fabian L. v. Superior Court (2013) 214 Cal.App.4th 1018, 1027 (Fabian L.) [noting unique developmental needs of infants and toddlers justifies a greater emphasis on establishing permanency and stability e

2015By statute, the juvenile court may not terminate a parent's reunification services at the six-month review hearing if it finds that "reasonable services have not been provided" to the parent. (§ 366.21, subd. (e); see Katie V. v. Superior Court (2005) 130 Cal.App.4th 586, 594 (Katie V.) ["Under the statutory scheme, review hearings are held every six months, at which time the juvenile court determines, among other things, whether the child welfare agency has offered the parent reasonable reunification services."].) " '[T]he focus of reunification services is to remedy those problems which led

2025(See In re S.B. (2004) 32 Cal.4th 1287, 1293 ; In re S.C. (2006) 138 Cal.App.4th 396 , 406.) 13 At the six-month review hearing, the juvenile court must return the dependent child to the custody of the parent unless it determines, by a preponderance of the evidence, that returning the child would create a substantial risk of detriment to the child’s safety, protection, or physical or emotional well-being. (§ 366.22, subd. (a); In re E.D. (2013) 217 Cal.App.4th 960, 965 .) “[T]he notion of detriment is at best a nebulous standard that depends on the context of the inquiry. . . . ‘It cannot mean

2021(Tracy J. v. Superior Court (2012) 202 Cal.App.4th 1415 , 1423- 1424.) Under this standard, “[w]e review the evidence most favorably to the prevailing party and indulge in all legitimate and reasonable inferences to uphold the court’s ruling.” (Mary B., supra, 218 Cal.App.4th at p. 1483 .) “In reviewing whether the record contains substantial evidence that returning [the child] to [the parent’s] custody would have been detrimental to [the child], we must keep in mind that the purpose of the reunification plan is ‘to overcome the problem that led to removal in the first place.’ ” (Ibid.) Here,

2022The child’s status, and the question of whether services should be extended for an additional period, must be reconsidered no less frequently than every six months. (§ 366, subd. (a)(1); Sara M. v. Superior Court (2005) 36 Cal.4th 998, 1009 .) At each review hearing, “there is a statutory presumption that the child will be returned to parental custody.” (In re Marilyn H. (1993) 5 Cal.4th 295, 308 .) A court, therefore, must return the child to parental custody at the six-month review hearing unless it finds by a preponderance of the evidence that doing so would “create a substantial risk of de

2022(In re Marilyn H. (1993) 5 Cal.4th 295 , 309–310.) “However, if the liberally construed allegations of the petition do not make a prima facie showing of changed circumstances and that the proposed change would promote the best interests of the child, the court need not order a hearing on the petition. [Citations.] The prima facie requirement is not met unless the facts alleged, if supported by evidence given credit at the hearing, would sustain a favorable decision on the petition.” (In re Zachary G. (1999) 5 At the six-month review hearing held on July 9, 2021, as to Matthew and M.B., the juv

2021(See Katie V. v. Superior Court (2005) 130 Cal.App.4th 586, 595 [at the six-month review hearing, the Department must prove it provided reasonable reunification services by clear and convincing evidence]; In re Monica C. (1995) 31 Cal.App.4th 296, 306 .) We review the juvenile court’s reasonable services finding for substantial evidence, i.e., evidence that is reasonable, credible and of solid value.

2015By statute, the juvenile court may not terminate a parent's reunification services at the six-month review hearing if it finds that "reasonable services have not been provided" to the parent. (§ 366.21, subd. (e); see Katie V. v. Superior Court (2005) 130 Cal.App.4th 586, 594 (Katie V.) ["Under the statutory scheme, review hearings are held every six months, at which time the juvenile court determines, among other things, whether the child welfare agency has offered the parent reasonable reunification services."].) " '[T]he focus of reunification services is to remedy those problems which led

2016The evidence must be viewed in light of the disabled parent’s response to services and demonstrated ability to safely care for the child, despite that parent’s labeled diagnosis, initial prognosis or eligibility for support services.” (Tracy J., supra, 202 Cal.App.4th at pp. 1424-1425.) 13 A parent is “not required to complain about the lack of reunification services as a prerequisite to the department fulfilling its statutory obligations.” (Mark N. v. Superior Court, supra, 60 Cal.App.4th at p. 1014 .) Even so, we note that mother testified at the six-month review hearing she didn’t agree wit

2015By statute, the juvenile court may not terminate a parent's reunification services at the six-month review hearing if it finds that "reasonable services have not been provided" to the parent. (§ 366.21, subd. (e); see Katie V. v. Superior Court (2005) 130 Cal.App.4th 586, 594 (Katie V.) ["Under the statutory scheme, review hearings are held every six months, at which time the juvenile court determines, among other things, whether the child welfare agency has offered the parent reasonable reunification services."].) " '[T]he focus of reunification services is to remedy those problems which led

2022(Id. at p. 947; In re D.M. (2012) 205 Cal.App.4th 283, 291 .) “The purpose of the California dependency system is to protect children from harm and to preserve families when safe for the child. (§ 300.2; In re Dakota H. (2005) 132 Cal.App.4th 212, 228 .) The focus during the reunification period is to preserve the family whenever possible. [Citation.] Until services are terminated, family reunification is the goal and the parent is entitled to every presumption in favor of returning the child to parental custody. (§§ 366.21, 366.22; [citation].)” (Tracy J. v. Superior Court (2012) 202 Cal.App.

2014(Tracy J. v. Superior Court (2012) 202 Cal.App.4th 1415, 1424 ; Angela S. v. Superior Court (1995) 36 Cal.App.4th 758, 763 .) Substantial evidence “means evidence that is ‘reasonable, credible and of solid value; it must actually be substantial proof of the essentials that the law requires in a particular case. [Citation.] In the absence of substantial evidence showing such detriment, the court is required to return the minor to parental custody. [Citation.]’ [Citation.]” (In re E.D. (2013) 217 Cal.App.4th 960, 966 .) There was substantial evidence presented at the six-month review hearing to

2025(See In re S.B. (2004) 32 Cal.4th 1287, 1293 ; In re S.C. (2006) 138 Cal.App.4th 396 , 406.) 13 At the six-month review hearing, the juvenile court must return the dependent child to the custody of the parent unless it determines, by a preponderance of the evidence, that returning the child would create a substantial risk of detriment to the child’s safety, protection, or physical or emotional well-being. (§ 366.22, subd. (a); In re E.D. (2013) 217 Cal.App.4th 960, 965 .) “[T]he notion of detriment is at best a nebulous standard that depends on the context of the inquiry. . . . ‘It cannot mean

2023Governing Principles and Standard of Review At the six-month review hearing, the juvenile court must return the child to his or her parent’s custody unless it finds, by a preponderance of the evidence, that doing so “would create a substantial risk of detriment to the safety, protection, or physical or emotional well-being of the child.” (§ 366.21, subd. (e)(1).) “A substantial risk of detriment means that ‘returning a child to parental custody represents some danger to the child’s physical or emotional well-being.’” (In re E.D. (2013) 217 Cal.App.4th 960, 965 (E.D.).) The Department bears the

2021(See Katie V. v. Superior Court (2005) 130 Cal.App.4th 586, 595 [at the six-month review hearing, the Department must prove it provided reasonable reunification services by clear and convincing evidence]; In re Monica C. (1995) 31 Cal.App.4th 296, 306 .) We review the juvenile court’s reasonable services finding for substantial evidence, i.e., evidence that is reasonable, credible and of solid value.

2020(M.V., supra, at p. 176; see also S.T. v. Superior Court (2009) 177 Cal.App.4th 1009, 1015-1016 .) If the court at the six-month review hearing exercises its discretion to set a 366.26 hearing within 120 days, it must terminate reunification services at that time. (§ 366.21, subd. (h).) But the juvenile court may not order a 366.26 hearing “unless there is clear and convincing evidence that reasonable services have been provided or offered to the parent or legal guardian.” (Id. at subd. (g)(1)(C)(ii).) Reunification services offered by the agency need not be “the best that might be provided in

2021The law favors reunification whenever possible. [Citation.] To achieve that goal, ordinarily a parent must be granted reasonable reunification services. [Citation.]” (In re Aryanna C. (2005) 132 Cal.App.4th 1234, 1242 .) Prior to the 366.26 hearing, there are periodic status reviews as ordered by the court, but not less frequently than every six months. (§ 366, subd. (a)(1).) Under section 366.21, subdivision (e)(1), at the six-month review hearing, the juvenile court must return the child to the parents’ physical custody “unless the court finds, by a 17 preponderance of the evidence, that the

2021The law favors reunification whenever possible. [Citation.] To achieve that goal, ordinarily a parent must be granted reasonable reunification services. [Citation.]” (In re Aryanna C. (2005) 132 Cal.App.4th 1234, 1242 .) Prior to the 366.26 hearing, there are periodic status reviews as ordered by the court, but not less frequently than every six months. (§ 366, subd. (a)(1).) Under section 366.21, subdivision (e)(1), at the six-month review hearing, the juvenile court must return the child to the parents’ physical custody unless the court finds, “by a preponderance of the evidence, that the re

2026(Ibid.; see David B. v. Superior Court (2004) 123 Cal.App.4th 768, 789 .) In addition, “[i]f the child is not returned to their parent or legal guardian, the court shall determine by clear and convincing evidence whether reasonable services that were designed to aid the parent or legal guardian in overcoming the problems that led to the initial removal and the continued custody of the child have been 4 provided or offered to the parent or legal guardian . . . .” (§ 366.21, subd. (e)(8); see In re A.O. (2025) 111 Cal.App.5th 1048 , 1061.) We review the juvenile court’s findings for substantial

2025In such cases, the juvenile court may, at the six-month review hearing, schedule a permanency planning hearing under section 366.26. (§ 366.21, subd. (e)(3).) “If, however, the court finds . . . that reasonable services have not been provided, . . . the court shall continue the case to the 12-month permanency hearing.” (Ibid.) “[T]he court shall determine by clear and convincing evidence whether reasonable services that were designed to aid the parent or legal guardian in overcoming the problems that led to the initial removal and the continued custody of the child have been provided or offere