Daisy H

In Daisy H. (2011) 192 Cal.App.4th 713, there had been only one episode of domestic violence, and it had occurred "at least two" and possibly seven years before the dependency proceedings were initiated. (Id. at p. 717.) "The children denied ever witnessing Father physically abuse Mother and there was no evidence that the alleged domestic violence incidents occurred in the children's presence." (Ibid.) The court noted that "physical violence between a child's parents may support the exercise of jurisdiction under section 300, subdivision (b) but only if there is evidence that the violence is ongoing or likely to continue and that it directly harmed the child physically or placed the child at risk of physical harm. " (Ibid.) Under the circumstances, the evidence did not support a finding that the children were "at a current substantial risk of physical harm." (Ibid.)