In re Michael E

In re Michael E. (2013) 213 Cal.App.4th 670 concerned the juvenile court's refusal to consider the father's girlfriend, who was the mother of the dependent child's half sibling, for placement as the dependent child's NREFM. (Id. at p. 674.) Rejecting the argument NREFM status is conferred through a mutual relative when there is no existing relationship between the child and the person seeking recognition as an NREFM, this court noted that section 362.7, by its plain terms, applies when the child has an existing relationship with an individual seeking NREFM status. (Michael E., at p. 675.) Notwithstanding the plain terms of the statute, this court concluded the juvenile court should have considered whether the child's placement with his half sibling's mother would further the legislative goals of allowing the child to remain in familiar surroundings, facilitating family reunification or providing a culturally sensitive environment to the child. (Id. at pp. 675-676.)