In re Dino E

In In re Dino E. (1992) 6 Cal.App.4th 1768, DCFS failed to provide the father with a reunification plan. Nonetheless, the dependency court believed that it had to terminate reunification services at the 18-month review hearing. The appellate court disagreed, finding that the lower court had the discretion to extend further services. It was careful to point out, however, that the fact DCFS had provided inadequate reunification services to the father did not require the juvenile court to grant a continuance and an extension of further services to him. The dependency court retained its discretion to determine "that the child's need for prompt resolution of his custody status outweighed any need for a continuance to provide further services to appellant." (Id. at p. 1779.) In that regard, "the court may consider the likelihood of success of any further reunification efforts, the fact that nearly a year has passed in Dino's life during the pendency of this appeal, . . . and the circumstance that appellant, as the parties have informed us at oral argument, is presently incarcerated." (Id. at pp. 1779-1780.)