In re Rebekah R

In In re Rebekah R. (1994) 27 Cal.App.4th 1638, a child less than two months old was found to be suffering from multiple fractures in her leg and ribs. (In re Rebekah R., supra, 27 Cal.App.4th 1638, 1642.) The evidence showed that the injuries had been caused by the child's mother while she was living with the father. The court reversed the termination of father's parental rights because the juvenile court had failed to make sufficient findings to warrant the denial of reunification services to the father, who did not injure the child. (In re Rebekah R., supra, 27 Cal.App.4th 1638, 1656.) In In re Rebekah R. (1994) counsel for the mother stated at the disposition hearing that due to the length of the mother's prison sentence, there was no real possibility she would be able to reunify with the child within 18 months. The court denied reunification services. On appeal, the court held the mother had waived any challenge to the denial of services: "In the absence of fraud, the admissions of an attorney in open court are binding upon the client. We believe counsel's statements made in the presence of her client eliminated from the case any issue regarding reunification services for the mother and waived for purposes of appeal any claim that the juvenile court's no-services order as to the mother was erroneous." ( Id. at pp. 1649- 1650.) The appellate court reversed the juvenile court's order denying reunification services to a father on the ground there was no evidence that services would not lead to successful reunification and found the social services agency had not investigated as required to assess whether reunification was likely to be successful.