In In re Joel H. (1993) 19 Cal.App.4th 1185, the court held that a great-aunt's appeal from dependency orders was not moot even though the dependency had been terminated and the child had been returned to his mother. The court reasoned that the juvenile court's adverse findings would have res judicata effect in any future dependency proceeding, preventing the appellant from offering her services as caregiver. "Under these circumstances," the court wrote, "a determination that the appeal is not moot will further the protection of the child, which is the primary purpose of juvenile dependency law." (Ibid.) The court said only that spanking the child "with a hand on his bottom" did not constitute serious physical abuse; the court noted, moreover, that there was no evidence that the child's de facto parents "struck Joel with objects" or "spanked Joel 'with a big belt.'" Joel H., therefore, does not support the proposition that hitting a young child with a belt does not constitute serious physical abuse.