In re R.C

In In re R.C. (2012) 210 Cal.App.4th 930, the case relied upon by the juvenile court here, the father had also committed multiple acts of domestic violence against the mother. None of the children saw the first violent episode. (Id. at p. 937.) One of the children was present during the second violent episode, but the two other children were not, although they learned about the incident from the mother. (Id. at pp. 936-937.) After the second episode, a social worker arranged for the mother and the children to go to a shelter, but the mother chose to go to San Francisco instead. (Id. at p. 935.) However, the social worker believed that the mother was "'focused on getting out of her relationship'" with the father. (Id. at p. 939.) The R.C. court rejected the father's claim that the evidence did not support a finding that the children were at substantial risk of physical harm due to the domestic violence. (R.C., supra, 210 Cal.App.4th at pp. 943-944.) The court distinguished cases involving single episodes of violence and emphasized that even though the parents had separated prior to the violence, the separation had not "diminished the risk." (Id. at p. 944.)