In re Jesse C

In In re Jesse C. (1989) 215 Cal. App. 3d 1384, the court dismissed an appeal from an order denying reunification services under the statutory scheme preceding the present one. The court concluded that the order was moot in view of a subsequent order terminating parental rights. ( Id. at p. 1388.) The controlling question, however, was whether the objections to the earlier order were " 'of such magnitude as to infect the outcome of the ensuing termination action.' " (Ibid.) The termination order there in issue rested on a statutory ground that could support termination independently of any procedures previously undertaken in the dependency proceeding. (Ibid.) Therefore the appeal was moot, because "even if the earlier order was defective, the termination proceeding could nonetheless have been independently initiated and the . . . result would have been the same." (Ibid.)