In re Lana S

In In re Lana S. (2012) 207 Cal.App.4th 94, "'problems that led to removal'" was construed to include drug abuse even though drug abuse was not alleged in the petition. There drug treatment was a "substantial component" of the mother's service plan. It was clear that her failure to submit to or satisfactorily complete drug testing and treatment was a factor leading to her failure to reunify with her older child. Thus, the court considered her addiction, manifested in the earlier case, and in part responsible for her failure to reunify, within the scope of "problems that led to the removal" of the other child as stated in section 361.5, subdivision (b). (Ibid.)