In re Daisy H

In In re Daisy H. (2011) 192 Cal.App.4th 713, juvenile court jurisdiction was based on a single incident of domestic violence by the father against the mother that occurred more than two years before the section 300 petition was filed and before the parents had separated and commenced marital dissolution proceedings. All of the children denied witnessing any domestic violence between the parents, and there was no evidence that any incidents of violence occurred in the children's presence. (Daisy H., supra, 192 Cal.App.4th at p. 717.) The appellate court concluded the evidence was insufficient to support jurisdiction premised on ongoing domestic violence or violence likely to continue, placing the child at risk of physical harm. (Ibid.)