Filed 7/17/24 In re M.W. CA4/1

NOT TO BE PUBLISHED IN OFFICIAL REPORTS

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COURT OF APPEAL, FOURTH APPELLATE DISTRICT

DIVISION ONE

STATE OF CALIFORNIA

In re M.W., a Person Coming Under 

the Juvenile Court Law.

SAN DIEGO COUNTY HEALTH 

AND HUMAN SERVICES 

AGENCY,

Plaintiff and Respondent,

v.

J.W. et al.,

Defendants and Appellants.

 D083860

 (Super. Ct. No. NJ15474B)

APPEAL from an order of the Superior Court of San Diego County, 

Harry M. Elias, Judge. (Retired Judge of the San Diego Sup. Ct. assigned by 

the Chief Justice pursuant to art. VI, § 6 of the Cal. Const.) Affirmed.

Sarah Vaona, under appointment by the Court of Appeal, for Defendant

and Appellant J.W.

Terence M. Chucas, under appointment by the Court of Appeal, for 

Defendant and Appellant Ma.W.
2

Claudia G. Silva, County Counsel, Lisa M. Maldonado, Chief Deputy 

County Counsel, and Natasha C. Edwards, Deputy County Counsel, for 

Plaintiff and Respondent.

INTRODUCTION

J.W. (Mother) appeals the juvenile court’s order denying her request at 

the 18-month review hearing to return her son, M.W., to her custody. (Welf. 

& Inst. Code,1 § 366.22.) Mother contends insufficient evidence supports the 

court’s finding there would be a substantial risk of detriment to M.W.’s

physical or emotional well-being if he returned to Mother’s care. Ma.W. 

(Father) joins Mother’s argument and states, “if this Court reverses the 

juvenile court’s findings and orders vis-à-vis [Mother’s] reunification services, 

then he requests that this Court remand the matter to the juvenile court with 

instructions for it to reinstate [Father’s] reunification services.”

As we shall discuss, we conclude Father has not provided a sufficiently

particularized argument in support of his contention that his reunification 

services should be reinstated, nor has he explained why Mother’s arguments 

apply equally to his claim. Thus, he has forfeited his claim on appeal. 

Moreover, we are unpersuaded by Mother’s challenge to the juvenile court’s 

finding of detriment, and we affirm.

1 All undesignated statutory references are to the Welfare and 

Institutions Code.
3

FACTUAL AND PROCEDURAL BACKGROUND

I.

Events Leading to Dependency

Mother and Father share three minor children, X.W., M.W., and G.W.

(collectively, the children).2 The family came to the attention of the San 

Diego County Health and Human Services Agency (Agency) when, between 

2018 and 2022, the Agency received over 40 referrals that included

allegations of physical and emotional abuse, and general neglect of the 

children. The Agency learned Mother had a history of drug use and mental 

health issues, and that the parents’ relationship included past incidents of 

domestic violence.

In July 2022, law enforcement was called to the family’s apartment 

complex on two occasions. On July 9, law enforcement received a complaint 

that the children were shooting a neighbor’s dog with a toy gun from their 

balcony. The children also threw toys at the neighbor and attempted to 

break windows. Officers tried to make contact with Mother but she did not 

respond to their questions and she told X.W. to close the apartment’s

windows.

On July 27, police again responded to the family’s apartment complex

when they received a complaint that the children were throwing diapers at 

passing vehicles. The reporting party also alleged one of the children was 

carrying a knife and threatening to stab a maintenance worker. When 

officers arrived, they observed M.W. running with a six-inch steak knife. 

G.W. hit one of the officers with a bag of dog feces. Mother told the officers 

2 At the time dependency proceedings were initiated, X.W. was 10 years 

old, M.W. was seven years old, and G.W. was six years old. X.W. and G.W. 

are not the subjects of this appeal and are discussed only when relevant.
4

the children had escaped from the apartment through the second story 

window and that she had no control over them.

G.W. and M.W. expressed an intent to “murder” the police officers. 

Based on this homicidal ideation, the officers took the children to the hospital 

for a psychological evaluation. Mother followed the officers to the hospital 

and blocked the ambulance bay with her car. She threatened to kill herself

during a verbal altercation with one of the officers.

X.W. disclosed a bruise on her leg at the hospital, and she alleged 

Mother caused the injury when she hit X.W. with an electrical cord. When an 

officer told X.W. he was sorry Mother hit her, X.W. responded, “it’s okay it 

happens a lot and I’m used to it.” Police arrested Mother for willful cruelty to 

a child (Pen. Code, § 273a), and the children were transported to Polinsky 

Children’s Center.

Father was not present during the incident. He told an Agency social 

worker that he resided at his workplace during the week and returned to the 

family home on the weekends. Father claimed the issues with the children 

were because of the neighbors, who were “bullying the kids, [and] telling [the] 

kids to jump off the balcony.”

II.

Initial Dependency Proceedings

The Agency petitioned the juvenile court pursuant to section 300, 

subdivision (b)(1). The petition alleged M.W. suffered, or was at substantial 

risk of suffering, serious physical harm or illness as a result of the parents’ 

inability to adequately supervise or protect him. Specifically, the petition 

discussed the July 2022 incident in which Mother left the children

unsupervised and officers observed M.W. running through the apartment 

complex with a knife.
5

At the August 2022 detention hearing, the juvenile court made a

prima facie finding that M.W. was a person described by section 300, 

subdivision (b). The court also found there was a substantial danger to 

M.W.’s health, or a risk he would suffer severe emotional damage, should he 

remain in the parents’ custody. Accordingly, the court detained M.W. in outof-home care, finding there were no reasonable means by which M.W.’s 

physical or emotional health could be protected absent his removal. The 

court permitted the parents liberal supervised visitation.

Thereafter, at the October 2022 jurisdiction and disposition hearing, 

the court sustained the allegations in the petition. The court ordered M.W. 

placed in a licensed group home or short-term residential therapeutic 

program, finding his return to the parents’ care would pose a substantial risk 

to his physical or emotional well-being. The court required the Agency to 

provide the parents reunification services. Mother’s case plan required her to 

participate in individual therapy, continue to see her psychiatrist, and 

comply with all medication prescribed by her psychiatrist.

III.

Reunification Period

During the initial reunification period, the Agency reported it struggled 

to work cooperatively with Mother. She repeatedly made allegations against 

Agency social workers, and she blamed her neighbors, the Agency, and law 

enforcement for the children’s removal from her care. Mother told an Agency

social worker, “I’m charging you with perjury. Something bad is going to 

happen. I got the police report and there are two different reports. I have to 

go to the FBI to sue the police department.” Then, during a virtual child 

family team meeting, Mother accused the social worker of falsifying 

documents and stated, “she’s lying. I’m out of here, fuck all you people.” 
6

Mother had to be muted several times during the meeting due to her frequent 

interruptions and inappropriate language.

M.W.’s physician contacted the Agency to disclose his concerns about 

Mother’s behavior during one of M.W.’s medical appointments. Mother

accompanied M.W. and his caregiver to the visit, and she was argumentative 

with the physician in M.W.’s presence. Mother claimed M.W.’s doctors were 

lying about changes to M.W.’s medication dosage, and “in a pressured, upset, 

tense, rambling and somewhat accusatory manner,” Mother asserted that 

another dosage was better.

The Agency reported concern at Mother’s behavior during her 

supervised visitation with the children. During a visit with X.W. and M.W., 

Mother made several accusations in the presence of the children, including:

the Agency social workers and the juvenile court judge had “all lied”; the 

neighbors in their apartment complex were “out to get them;” and the 

children could not return home because the social worker received money for 

children involved in dependency proceedings. Mother also faulted X.W. for 

the dependency case, telling her, “you did things to put us here.” X.W.’s 

caregivers refused to supervise visitation with Mother after she made 

multiple disparaging comments about them and disclosed their confidential 

address to the police.

Consequently, in February 2023, the Agency filed a section 388 petition 

requesting the court modify its prior order permitting Mother liberal 

supervised visitation. The Agency asked the court to require Mother’s 

visitation with M.W. to be supervised in a therapeutic setting only. The 

Agency cited to Mother’s defiant and combative behavior towards M.W.’s 

medical team and the Agency’s staff. At the six-month review hearing, the 
7

court granted the Agency’s request. The court also required Mother and the 

children to undergo psychological evaluations.

M.W.’s psychological evaluation noted a history of aggression and 

behavioral issues that it attributed to “past parental neglect, chaos and 

general lack of structure in the family home.” He was diagnosed with 

attention deficit/hyperactive disorder, and he was previously diagnosed with 

oppositional defiant disorder (ODD). The parents had attempted to treat his 

ODD with “essential oil[s],” rather than medication.

Examples of M.W.’s behavioral issues during the reunification period 

included incidents in which he slapped another student in the face at school, 

threw his caregiver’s cat, smeared feces on his caregiver’s walls, and shouted 

racial epithets at his caregiver. M.W. and his siblings displayed violent and 

dangerous behavior during their visitation. Nonetheless, the Agency 

reported that after M.W. commenced therapy and received increased 

medication, his behavior started to improve.

Mother’s therapist diagnosed her with posttraumatic stress disorder 

and reported that she exhibited symptoms of borderline personality disorder. 

Her therapist opined that Mother struggled to take “ownership of her issues 

and how they impact the relationship with her kids.” She believed Mother’s

behavior had contributed to the children’s psychological issues.

In a September 2023 report, the Agency averred that Mother’s behavior 

with the Agency, and her conduct during supervised visitation with the 

children, had improved. Mother’s therapist reported she was developing 

insight into her behavior and becoming less reactive. She completed an 

anger management class, a conflict resolution class, and parenting classes. 

Consequently, the Agency considered the possibility of expanding Mother’s 

visitation with X.W. to be unsupervised.
8

However, on September 27, 2023, Mother was placed on an involuntary

psychiatric hold. Her treatment team informed the Agency that she was 

“displaying paranoid ideations and was very combative and not cooperating.” 

Mother accused her therapist of attempting to sex traffic her, and a nurse at 

the hospital reported she was “[v]ery agitated, talking about human 

trafficking, [and] paranoid about everybody there.” Mother told the Agency 

that she believed someone tried to kidnap her. When an Agency social 

worker asked Mother if she thought she would test positive for 

methamphetamine or fentanyl, Mother responded, “[p]robably.”

At the 12-month review hearing, the juvenile court again found M.W. 

could not be returned to the parents’ care without a substantial risk of 

detriment to his physical or emotional well-being. The court ordered Mother 

to continue to comply with the Agency’s case plan and permitted her 

supervised visitation. The court then set an 18-month review hearing 

pursuant to section 366.22.

After the 12-month review hearing, M.W.’s caregiver reported that

Mother appeared to be under the influence during a supervised visit with 

M.W. She observed Mother “driving reckless, running up on curbs, stopping 

hard at the last minute.” The caregiver heard Mother say that she “didn’t 

want any of the kids back,” and later say, “maybe I’ll take [M.W.] back.”

Mother was hospitalized in November 2023 related to an infection on

her hand. She was discharged from the hospital after she became verbally 

combative with hospital staff. The maternal grandmother reported that 

hospital staff found drug paraphernalia and opiates in Mother’s bag.

M.W.’s caregiver suffered a medical emergency in November 2023 that 

required M.W. to be removed from her care and placed at Polinsky Children’s 

Center. M.W.’s behavior then began to deteriorate. During one visit between 
9

M.W. and his siblings at the maternal grandmother’s home, the children

caused extensive damage to her residence, yard, and car. M.W. keyed his 

grandmother’s car with the words “Fuck Bitch.” At school, M.W. called his 

classmates racial slurs and he assaulted one of his classmates. School staff 

had to escort M.W. around the campus to protect other students from M.W.’s 

hostility.

The Agency reported it was unable to find suitable placement for M.W. 

because of his escalating behavior. M.W. was verbally and physically 

assaultive with staff and his peers at Polinsky Children’s Center. M.W. hit, 

kicked, and spit at the staff, tried to stab them with various objects, 

destroyed property, set off fire alarms, and used racial slurs. Due to M.W.’s

complex behavioral needs and the instability of Mother’s mental health, the 

Agency assessed that M.W. faced a significant risk of harm if he returned to 

Mother’s care.

That Agency reported that Father had inconsistent visitation with the 

children throughout the dependency case. He did not visit them at all 

between August 2023 and November 2023. Thus, the Agency opined that 

M.W.’s placement with Father would also create a substantial risk of harm,

and it recommended that M.W. remain in out-of-home care.

IV.

Contested Section 366.22 Hearing

On March 22, 2024, the juvenile court conducted a contested 18-month 

review hearing. (§ 366.22, subd. (a).) Without objection, the court received 

into evidence a court-appointed special advocate report and several Agency

reports. The court heard testimony from Mother and the Agency’s social 

worker. Father stipulated that, if called upon to testify, he would testify he

had been visiting M.W. every Sunday.
10

Mother testified she had been in therapy for three or four years. 

However, as of the section 366.22 hearing, she was no longer seeing her 

therapist and her psychiatric services had recently been terminated. Mother 

reported that she had developed a safety plan with her psychiatrist, and she 

proffered she was able to reach out to a network of resources if she 

experienced any mental health issues. She stated that she recently signed up 

with a new therapist, and she was in the process of obtaining housing.

Mother expressed that she did not believe all three children should be 

returned to her care because “it would be too much for [her] to handle all 

three children right now.” However, Mother asked the court to return M.W. 

to her custody. She testified that she shared a “strong relationship” with 

M.W., and she believed she was able to “focus on one child.”

On cross-examination, Mother testified that her prior therapist falsely 

accused her of meeting a boyfriend at 7-Eleven and had falsely accused her of 

making claims that she was being sex-trafficked. She also stated her 

neighbors had called the police simply because Mother raised her voice. 

Mother alleged the police “kidnapped” her children because she refused to 

open the door.

The Agency social worker testified the Agency was recommending 

M.W.’s placement with a willing relative or a foster home because he was not 

suitable for adoption at the time. She explained the Agency was not 

recommending M.W.’s return to Mother’s care because of Mother’s instability 

during the proceedings. She cited to Mother’s accusations against her 

therapist and her accusations that the Agency had stolen her children. 

Additionally, she opined that Mother had not taken accountability for the 

issues that led to dependency.
11

Following the presentation of evidence, counsel for the Agency asked 

the court to “find that it would be detrimental to return the children to either 

parent.” He pointed to Mother’s testimony in which she accused the police of 

kidnapping her children. Counsel proffered that Mother’s testimony 

demonstrated there had been no progress in this case “that would show the 

children can be safely placed with” either parent.

M.W.’s guardian ad litem agreed that M.W.’s return to Mother’s care 

would be detrimental. He expressed concern at Mother’s testimony that her 

children had been kidnapped by the police, and he opined that Mother’s 

mental health had been an issue throughout the case. However, the 

guardian ad litem represented that M.W. wished to be returned to Mother’s 

care.

Mother asked the court to continue her reunification services for X.W. 

and G.W., and to return M.W. to her care. She argued the evidence 

demonstrated she was safe and that she had not harmed the children. She 

proffered that she understood M.W.’s needs and was committing to meeting 

them.
12

After considering the parties’ arguments, the court ordered foster care 

as the permanent plan for M.W. and terminated reunification services. The 

court found the evidence clearly demonstrated neither party was ready for 

the return of “all of the kids or any one of the kids,” and that M.W.’s return to 

the parents’ care would create a substantial risk of detriment to his physical 

or emotional well-being. However, the court commended Mother on her 

insight that she was not ready for the return of all three children. The court 

speculated that there may be a point in the future in which M.W. could safely 

return to Mother’s care if she consistently engaged with her therapist and 

demonstrated an understanding of M.W.’s needs.

This appeal followed.

DISCUSSION

Mother argues insufficient evidence supports the juvenile court’s 

finding that M.W.’s return to Mother’s custody would create a substantial 

risk of detriment to his physical or emotional well-being. Father purports to 

join Mother’s arguments and posits, “if this Court reverses the juvenile 

court’s findings and orders vis-à-vis [J.W.], returns custody of [M.W.] to her 

and/or reinstates [J.W.’s] reunification services, then he requests that this 

Court remand the matter to the juvenile court with instructions for it to 

reinstate [Father’s] reunification services.” We disagree with their 

contentions and affirm.

During dependency proceedings, the juvenile court must return a child 

to the care of their parent at the 18-month hearing unless the court 

determines the return of the child “would create a substantial risk of 

detriment to the safety, protection, or physical or emotional well-being of the 

child.” (§ 366.2, subd. (a).) The Agency bears the burden of establishing

detriment. (In re Yvonne W. (2008) 165 Cal.App.4th 1394, 1400 (Yvonne W.).)
13

The standard for showing detriment is “ ‘a fairly high one. It cannot mean 

merely that the parent in question is less than ideal, did not benefit from the 

reunification services as much as we might have hoped, or seems less capable 

than an available foster parent or other family member.’ [Citation.] Rather, 

the risk of detriment must be substantial, such that returning a child to 

parental custody represents some danger to the child’s physical or emotional 

well-being.” (Ibid.)

We review a juvenile court’s finding of a substantial risk of detriment 

for substantial evidence. (Yvonne W., supra, 165 Cal.App.4th at p. 1400.) 

Under this standard, “we may look only at whether there is any evidence, 

contradicted or uncontradicted, which would support the trier of fact’s 

conclusion. We must resolve all conflicts in favor of the court’s 

determination, and indulge all legitimate inferences to uphold the court’s 

order. Additionally, we may not substitute our deductions for those of the 

trier of fact.” (In re John V. (1992) 5 Cal.App.4th 1201, 1212.) The party 

challenging the juvenile court’s detriment finding has the burden to show 

that substantial evidence does not support the finding. (In re L.Y.L. (2002) 

101 Cal.App.4th 942, 947.)

Here, as an initial matter, Father has failed to provide particularized 

legal argument in support of his contentions, and he has therefore waived his 

claim on appeal. “Appellate counsel for the party purporting to join some or 

all of the claims raised by another are obligated to thoughtfully assess 

whether such joinder is proper as to the specific claims and, if necessary, to 

provide particularized argument in support of his or her client’s ability to 

seek relief on that ground. If a party’s briefs do not provide legal argument 

and citation to authority on each point raised, ‘ “the court may treat it as 

waived, and pass it without consideration. [Citations.]” ’ [Citation.] ‘Joinder 
14

may be broadly permitted [citation], but each appellant has the burden of 

demonstrating error and prejudice [citations].’ ” (People v. Bryant, Smith and 

Wheeler (2014) 60 Cal.4th 335, 363-364.)

Father avers that he joins the arguments set forth in J.W.’s opening 

brief, and he contends this court should reverse the juvenile court’s order 

terminating Father’s reunification services if we reverse the court’s 

placement order or services order as to Mother. However, Father does not 

argue that insufficient evidence supports the court’s order terminating his 

reunification services, nor does he explain why a reversal of the court’s 

detriment finding as to Mother would warrant the reinstatement of his

services. In other words, Father has not explained why Mother’s arguments 

apply equally to both parties, nor has Father proffered any legal authority or 

argument in support of his position. (Nelson v. Avondale Homeowners Assn. 

(2009) 172 Cal.App.4th 857, 862 [“Appellate briefs must provide argument 

and legal authority for the positions taken. ‘When an appellant fails to raise 

a point, or asserts it but fails to support it with reasoned argument and 

citations to authority, we treat the point as waived.’ ”].) Accordingly, Father’s 

briefing does not attempt to meet his burden of demonstrating error on 

appeal, and we therefore treat his claim as waived.

Nevertheless, even assuming Father’s joinder was proper, we conclude 

substantial evidence supports the juvenile court’s detriment finding. “In 

evaluating detriment, the juvenile court must consider the extent to which 

the parent participated in reunification services. [Citations.] The court must 

also consider the efforts or progress the parent has made toward eliminating 

the conditions that led to the child’s out-of-home placement.” (Yvonne W., 

supra, 165 Cal.App.4th at p. 1400, italics added.)
15

Here, although Mother did complete various aspects of her case plan, 

including an anger management class and parenting classes, her testimony 

during the section 366.22 hearing demonstrated a lack of insight into the 

issues that led to dependency and M.W.’s removal. She testified that her 

therapist made false allegations against her and that the police had 

kidnapped her children. She did not acknowledge the children’s dangerous 

behavior when they were left unsupervised at the family’s apartment 

complex, but instead claimed the neighbors contacted police simply because 

she raised her voice.

Moreover, Mother ceased participating in therapy and meeting with 

her psychiatrist as of the section 366.22 hearing. Mother’s case plan required 

her to participate in therapy, and her behavior throughout the dependency 

proceedings demonstrated a need for such services to facilitate M.W.’s safe 

return to her care. Mother repeatedly demonstrated hostility towards Agency 

social workers, M.W.’s doctors, the children’s caregivers, and her own 

therapist, often in the presence of the children. M.W.’s high level of needs 

required therapeutic intervention, and Mother’s behavior, when left 

untreated, demonstrated she was unable to cooperate with M.W.’s treatment 

team and effectively meet his needs.

Although Mother did experience a period of improvement, she was later 

placed on an involuntary psychiatric hold. Then, around seven weeks after 

the psychiatric hold, she was discharged from a hospital due to her combative 

behavior with the hospital’s staff. The maternal grandmother reported that 

drug paraphernalia was found in Mother’s belongings during this incident. 

That same month, M.W.’s caregiver disclosed that Mother appeared to be 

under the influence during her supervised visit with M.W. These incidents 
16

demonstrate a lack of progress towards eliminating the issues that led to 

M.W.’s removal from the home.

Moreover, “while the court must consider the extent the parent has 

cooperated with the services provided and the efforts the parent has made to 

correct the problems which gave rise to the dependency (§ 366.22, subd. (a)), 

the decision whether to return the child to parental custody depends on the 

effect that action would have on the physical or emotional well-being of the 

child.” (In re Joseph B. (1996) 42 Cal.App.4th 890, 899.) In this regard, 

“[d]etriment can be shown many different ways.” (A.H. v. Superior Court

(2010) 182 Cal.App.4th 1050, 1059.)

M.W.’s behavioral issues throughout the dependency proceedings were 

significant, and he required a high level of care that Mother failed to 

demonstrate she was able to provide. M.W. committed repeated acts of 

violence towards his peers and siblings, destroyed property, and shouted 

racial epithets at other children and his caregiver. Although M.W.’s 

psychological evaluation indicated he was capable of overcoming the negative 

effects of his past family dysfunction that had contributed to his behavioral 

issues, the Agency did not believe M.W. would have the structure and 

stability to safely progress if he was returned to Mother’s care at the time of 

the section 366.26 hearing. The evidence provides ample support for this 

assessment and the juvenile court’s ultimate finding that M.W.’s return to 

Mother’s care would endanger his physical or emotional well-being.

Mother’s reliance on David B. v. Superior Court (2004) 123 Cal.App.4th 

768 (David B.), and Yvonne W., supra, does not compel a contrary result.

In David B., the juvenile court found at the 18-month review hearing

that a dependent should not be returned to the parent’s care even though the 

parent had done “virtually everything [the Agency] requested of him, and 
17

then some.” (David B., supra, 123 Cal.App.4th at p. 772.) The juvenile

court’s finding of detriment stemmed from evidence of another adult living in 

the parent’s residence, the parent’s frequent consultation with the foster 

parent and social worker regarding the child’s care, and the court’s belief that

the parent was “simply unprepared” for the child’s return. (Id. at pp. 790-

794.). On appeal, the David B. court concluded this evidence was insufficient 

to establish detriment. (Id. at p. 798.) The court clarified that, in evaluating 

detriment, the juvenile court should consider the parent’s “grasp of the 

important parenting concepts—things such as a child’s need for security, 

adequate nutrition and shelter, freedom from violence, proper sanitation, 

healthcare, and education.” (Id. at p. 790.)

In Yvonne W., supra, a child became a dependent of the juvenile court 

due to the parent’s drug use. (Yvonne W., supra, 165 Cal.App.4th at p. 1398.) 

The parent made progress in her reunification plan and obtained stable 

housing at a shelter that permitted her to reside with her children. (Id. at 

pp. 1397-1398.) However, at the 18-month review hearing, the Agency 

recommended against returning the child to the parent’s care because, among 

other factors, the parent and child still needed to participate in conjoint 

therapy. (Id. at p. 1399.) The juvenile court adopted the Agency’s 

recommendation and made a finding of detriment. (Ibid.) On appeal, the 

Yvonne W. court reversed, concluding that although conjoint therapy may 

have benefitted the parent-child relationship, “[n]othing in the record 

supports a finding that without conjoint therapy, [the child] will be at 

substantial risk of detriment in [the parent’s] care.” (Id. at p. 1403.)

The facts of this case are much different than those in David B. and 

Yvonne M. The evidence of Mother’s mental and emotional instability was 

significant, and her treatment provider opined that her behavior had
18

contributed to the M.W.’s psychological issues. These psychological issues led 

to incidents in which M.W. acted violently towards other children and 

expressed an intent to murder police officers. Thus, the requirement that 

Mother attend therapy was not merely to benefit the parent-child 

relationship like in Yvonne M., but was intended to ensure Mother’s mental 

stability so she was able to safely meet M.W.’s high level of needs. And 

unlike David B., Mother’s behavior did not suggest she was simply 

unprepared for M.W.’s return. Her behavior reflected an inability to 

maintain the stability and consistency that M.W. required to safely interact 

with other children, attend school, and return to the family home.

In sum, the evidence of detriment before the juvenile court was 

substantial and demonstrated that the return of M.W. to Mother’s care posed 

a danger to his well-being. Mother’s lack of progress in eliminating the 

issues that led to M.W.’s removal supports the conclusion that she was 

unable to provide the protection and security M.W. required as he struggled 

with significant behavioral issues. Although we do not discount Mother’s 

efforts at reunification that she emphasizes in her briefing on appeal, or the 

challenges she faced managing M.W.’s behavior, we must resolve all 

inferences from the evidence in favor of the juvenile court’s finding. Doing so,

we conclude substantial evidence supports the juvenile court’s finding and we 

affirm.
19

DISPOSITION

The juvenile court’s order is affirmed.

O’ROURKE, J.

WE CONCUR:

HUFFMAN, Acting P. J.

CASTILLO, J.