In re Hailey T

In In re Hailey T. (2012) 212 Cal.App.4th 139, the juvenile court did not consider any alternatives to removal other than noting "its concern that both children were too young to protect themselves from abuse and the alternative of moving the parents (or one of them) into the grandparents' home would not provide for adequate supervision to protect the children." (Ibid.) Under these circumstances, the appellate court found insufficient evidence to support the juvenile court's determination no less drastic alternatives to removal existed, noting "courts have recognized that less drastic alternatives to removal may be available in a given case including returning a minor to parental custody under stringent conditions of supervision by the agency such as unannounced visits." (Ibid.)