In re Catherine S

In In re Catherine S. (1991) 230 Cal. App. 3d 1253, the Court of Appeal found section 361.5, subdivisions (b)(2) and (c) engrafted the competency requirements for the evaluators contained in Civil Code section 232, subdivision (a)(6), the precursor to Family Code sections 7820 et seq. Since one of the psychologists who testified in that case was unquestionably not properly licensed, the court found the evidence was insufficient to support the denial of reunification services. Because the issue was insufficiency of the evidence, the court refused to apply a harmless error analysis. ( In re Catherine S., supra, 230 Cal. App. 3d at pp. 1257-1258.)