Florida Statutes

Fla. Stat. § 39.603 (2025)

Court approvals of case planning.

✓ 2025 Florida Statutes — current through the 2025 Regular Session
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39.603 Court approvals of case planning.
(1) All case plans and amendments to case plans must be approved by the court. At the hearing on the case plan, which shall occur in conjunction with the disposition hearing unless otherwise directed by the court, the court shall determine:
(a) All parties who were notified and are in attendance at the hearing, either in person or through a legal representative. The court may appoint a guardian ad litem under Rule 1.210, Florida Rules of Civil Procedure, to represent the interests of any parent, if the location of the parent is known but the parent is not present at the hearing and the development of the plan is based upon the physical, emotional, or mental condition or physical location of the parent.
(b) If the plan is consistent with previous orders of the court placing the child in care.
(c) If the plan is consistent with the requirements for the content of a plan as specified in this chapter.
(d) In involuntary placements, whether each parent was notified of the right to counsel at each stage of the dependency proceedings, in accordance with the Florida Rules of Juvenile Procedure.
(e) Whether each parent whose location was known was notified of the right to participate in the preparation of a case plan and of the right to receive assistance from any other person in the preparation of the case plan.
(f) Whether the plan is meaningful and designed to address facts and circumstances upon which the court based the finding of dependency in involuntary placements or the plan is meaningful and designed to address facts and circumstances upon which the child was placed in out-of-home care voluntarily.
(2) When the court determines that any of the elements considered at the hearing related to the plan have not been met, the court shall require the parties to make necessary amendments to the plan under s. 39.6013. The amended plan must be submitted to the court for review and approval within 30 days after the hearing. A copy of the amended plan must also be provided to each party, if the location of the party is known, at least 3 business days before filing with the court.
(3) A parent who has not participated in the development of a case plan must be served with a copy of the plan developed by the department, if the parent can be located, at least 72 hours prior to the court hearing. Any parent is entitled to, and may seek, a court review of the plan prior to the initial judicial review and must be informed of this right by the department at the time the department serves the parent with a copy of the plan. If the location of an absent parent becomes known to the department, the department shall inform the parent of the right to a court review at the time the department serves the parent with a copy of the case plan.
History.s. 9, ch. 87-289; s. 32, ch. 88-337; s. 26, ch. 94-164; s. 17, ch. 95-228; s. 76, ch. 98-403; s. 37, ch. 99-193; s. 27, ch. 2000-139; s. 18, ch. 2006-86.
Note.Former s. 39.452(5).
Notes of Decisions
Cited in 9 cases, 1999–2017 · leading case: Bde v. Dept. of Child. & Fam. Ser., 829 So. 2d 359 (Fla. 1st DCA 2002).
Bde v. Dept. of Child. & Fam. Ser., 829 So. 2d 359 (Fla. 1st DCA 2002). · cites it 2× “See § 39.603(2), Fla. Stat. (2000). [5] On March 21, 2000, the trial court entered an order granting B.”
DM v. Dept. of Child. & Families, 807 So. 2d 90 (Fla. 5th DCA 2002). “Section 39.603(1)(f) provides: (1) At the hearing on the plan .”
In Re Gs, 84 So. 3d 1231 (Fla. 2d DCA 2012). · cites it 3× “The Mother does not challenge the adjudication of dependency, but she argues that the trial court's acceptance of the Department's case plan violates section 39.603(1)(f), Florida Statutes (2011), because the case plan does not meaningfully address the facts and circumstances…”
C.T. v. Dep't of Child. & Fam. Servs. & Guardian, 84 So. 3d 1231 (Fla. 2d DCA 2012). · cites it 3× “The Mother does not challenge the adjudication of dependency, but she argues that the trial court’s acceptance of the Department’s case plan violates section 39.603(l)(f), Florida Statutes (2011), because the case plan does not meaningfully address the facts and circumstances…”
J.Z. v. Dep't of Child. & Fam. Servs., 106 So. 3d 976 (Fla. 2d DCA 2013). “” § 39.603(l)(f). Later, the court’s determination whether there has been “substantial compliance” with the case plan will turn on whether “the circumstances which caused the creation of the case plan have been significantly remedied.”
MW v. Davis, 722 So. 2d 966 (Fla. 4th DCA 1999). “" That case plan must be approved by the court, section 39.603, and judicially reviewed on a regular basis.”
K. C. Mother of P.C., Minor Child v. Dep't of Child. & Families, 220 So. 3d 579 (Fla. 1st DCA 2017). · cites it 2× “See § 39.603(1), Fla. Stat. (2017); M.M. v. Dep’t of Children & Families, 189 So.”
M.P., the father v. Dep't of Child. & Families, 159 So. 3d 341 (Fla. 4th DCA 2015). · cites it 3× “” § 39.603(1)®, Fla. Stat. (2014). “Generic case plans that do not consider the needs and circumstances of the individual family violate these statutory directives, as does a case plan for one parent that simply mirrors the case plan for the other without considering each…”
S.S. v. Dep't of Child. & Families, 75 So. 3d 818 (Fla. 5th DCA 2011). “§ 39.603(1)©, Fla. Stat. (2010). We read these express general directives from the legislature as authorizing DCF to include (and the circuit court to approve) a no new law violation condition so long as it is related to correcting a parent’s behavior or to acts resulting in…”
— 39.603(1) — 3 cases
K. C. Mother of P.C., Minor Child v. Dep't of Child. & Families, 220 So. 3d 579 (Fla. 1st DCA 2017). “See § 39.603(1), Fla. Stat. (2017); M.M. v. Dep’t of Children & Families, 189 So.”
M.P., the father v. Dep't of Child. & Families, 159 So. 3d 341 (Fla. 4th DCA 2015). “” § 39.603(1)®, Fla. Stat. (2014). “Generic case plans that do not consider the needs and circumstances of the individual family violate these statutory directives, as does a case plan for one parent that simply mirrors the case plan for the other without considering each…”
S.S. v. Dep't of Child. & Families, 75 So. 3d 818 (Fla. 5th DCA 2011). “§ 39.603(1)©, Fla. Stat. (2010). We read these express general directives from the legislature as authorizing DCF to include (and the circuit court to approve) a no new law violation condition so long as it is related to correcting a parent’s behavior or to acts resulting in…”
— 39.603(1)(f) — 2 cases
DM v. Dept. of Child. & Families, 807 So. 2d 90 (Fla. 5th DCA 2002). “Section 39.603(1)(f) provides: (1) At the hearing on the plan .”
In Re Gs, 84 So. 3d 1231 (Fla. 2d DCA 2012). “The Mother does not challenge the adjudication of dependency, but she argues that the trial court's acceptance of the Department's case plan violates section 39.603(1)(f), Florida Statutes (2011), because the case plan does not meaningfully address the facts and circumstances…”
— 39.603(2) — 1 case
Bde v. Dept. of Child. & Fam. Ser., 829 So. 2d 359 (Fla. 1st DCA 2002). “See § 39.603(2), Fla. Stat. (2000). [5] On March 21, 2000, the trial court entered an order granting B.”
— 39.603(l)(f) — 3 cases
C.T. v. Dep't of Child. & Fam. Servs. & Guardian, 84 So. 3d 1231 (Fla. 2d DCA 2012). “The Mother does not challenge the adjudication of dependency, but she argues that the trial court’s acceptance of the Department’s case plan violates section 39.603(l)(f), Florida Statutes (2011), because the case plan does not meaningfully address the facts and circumstances…”
J.Z. v. Dep't of Child. & Fam. Servs., 106 So. 3d 976 (Fla. 2d DCA 2013). “” § 39.603(l)(f). Later, the court’s determination whether there has been “substantial compliance” with the case plan will turn on whether “the circumstances which caused the creation of the case plan have been significantly remedied.”
M.P., the father v. Dep't of Child. & Families, 159 So. 3d 341 (Fla. 4th DCA 2015). “” § 39.603(1)®, Fla. Stat. (2014). “Generic case plans that do not consider the needs and circumstances of the individual family violate these statutory directives, as does a case plan for one parent that simply mirrors the case plan for the other without considering each…”
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