S.T. v. Superior Court

In S.T. v. Superior Court (2009) 177 Cal.App.4th 1009, the minor was detained at birth and placed with her maternal grandparents. Both mother and father were incarcerated. Father had received services, but was unable to comply with the court orders that he participate in drug treatment, because the prison did not offer such a program. Father was due to be released from custody and, at the six-month review hearing, requested an additional six months of services. The juvenile court terminated reunification services, believing it did not have the discretion to continue them because father had not complied with court-ordered treatment. (S.T. v. Superior Court, supra, 177 Cal.App.4th at pp. 1014-1015.) The reviewing court reversed, directing the juvenile court to exercise its discretion to continue or terminate services, based upon the recent statutory amendments. (Id. at p. 1018.)