In In re Chantal S. (1996) 13 Cal.4th 196, a visitation order provided that visitation should be "facilitated" by the child's therapist and visitation could begin when the parent's chosen therapist determined the parent had made "satisfactory" progress. (Id. at p. 213.) The juvenile court awarded sole legal and physical custody of Chantal to her mother and terminated dependency proceedings. The court granted Chantal's father visitation rights, conditioned on his participation in psychotherapy, his progress in that therapy and his payment for that therapy. (Chantal S., supra, 13 Cal.4th at pp. 201-202.) The father challenged the court's exit order on a number of grounds, all of which were rejected by the Supreme Court. As relevant here, the Supreme Court rejected the father's claim that the juvenile court had no authority to condition visitation on his participation in counseling. The court found that section 362.4 " 'implicitly authorizes' " a juvenile court to make collateral orders " 'reasonably related to the custody and visitation orders.' " (Id. at pp. 202-204.) The court also rejected a claim that the counseling condition violated his due process rights by unlawfully delegating judicial power to therapists. (Id. at pp. 213-214.) The court noted that the father did not contest the view that, given the record in the juvenile court, the court would have acted within its discretion in denying him any visitation and commented that "the fact that the juvenile court rejected that course, and instead issued the restrictive order challenged now, amounts to a windfall to father, not a violation of his rights." (Id. at p. 214.) The California Supreme Court held the order did not constitute an improper delegation of judicial authority to the therapists. (Id. at pp. 213-214.) The court reasoned the order gave the therapists only limited discretion and left to the juvenile court the final decision as to whether visitation should begin. (Ibid.) The exit orders "specified that visitation was to be 'facilitated' by Chantal's therapist, and that visitation was to begin when father's chosen therapist determined father had made 'satisfactory progress for a time.' " (Id. at p. 213.) The Supreme Court rejected the contention the order was an improper delegation of judicial authority to the therapists. The court concluded the "order gives Chantal's therapist no discretion whatsoever. The directive that Chantal's therapist 'facilitate' visitation appears designed merely to mandate that Chantal's therapist cooperate with the court's order that visitation occur once certain conditions are met." (Ibid.) The court further concluded that assuming arguendo the order vested too much judicial discretion to the father's therapist, he suffered no prejudice because he conceded it would have been within the court's discretion to deny him visitation altogether. (Id. at p. 214.) The California Supreme Court rejected a father's argument that the juvenile court's visitation order improperly delegated judicial authority to the minor's therapists. (Chantal S., supra, 13 Cal.4th at p. 213.) The juvenile court's order stated " 'Visitation . . . for father . . . to be facilitated by Chantal's therapist . . .Before visitation with father and his daughter can occur. . .father must attend therapy regularly and make satisfactory progress for a time before any visits as determined by his therapist." (Id. at p. 202, brackets in original.) Our high court explained that the visitation order gave Chantal's therapist "no discretion whatsoever" because the order was apparently designed to "mandate that Chantal's therapist cooperate with the court's order that visitation occur once certain conditions are met." (Id. at p. 213.) As the Chantal S. court explained, the "juvenile court apparently concluded that to protect Chantal, visitation should not begin until father makes sufficient progress in his own therapy. A juvenile court faced with this situation has two options. First, if circumstances warrant, it could deny father visitation, which in effect would require him to later move the family court to amend the order if he wished to secure visitation. In this regard, we note that father does not contest the position of Riverside County Department of Public Social Services . . . that on this record the juvenile court would have been within its discretion to simply deny father any visitation. Alternatively, the juvenile court could issue the order it did, specifying that visitation commence in a carefully restricted setting when father's chosen therapist determines that father has progressed satisfactorily." (Chantal S., supra, 13 Cal.4th at pp. 213-214, ) In In re Chantal S. (1996) the dependency proceedings were initiated based on evidence the father was violent and the mother was unable to protect the minor, Chantal. The court held a juvenile court, when terminating its dependency jurisdiction, could issue an order conditioning visitation on a parent's participation in counseling without being bound by the requirements of Family Code section 3190, which governs family court counseling orders. (Chantal S., supra, 13 Cal.4th at p. 200.) It explained, "At the outset it is helpful to clarify the distinction between a 'juvenile court,' and its orders, and a 'family court,' and its orders. A 'juvenile court' is a superior court exercising limited jurisdiction arising under juvenile law. Dependency proceedings in the juvenile court are special proceedings with their own set of rules, governed, in general, by the Welfare and Institutions Code. By contrast, 'family court' refers to the activities of one or more superior court judicial officers who handle litigation arising under the Family Code. It is not a separate court with special jurisdiction, but is instead the superior court performing one of its general duties. The two courts have separate purposes. The family court is established to provide parents a forum in which to resolve, inter alia, private issues relating to the custody of and visitation with children. In that setting, parents are presumed to be fit and capable of raising their children. (Fam. Code, 3061.) The juvenile court, by contrast, provides the state a forum to 'restrict parental behavior regarding children, . . . and . . . to remove children from the custody of their parents or guardians.' When, as in this matter, a juvenile court hears a dependency case under section 300 of the Welfare and Institutions Code, the court deals with children who have been seriously abused, abandoned, or neglected. The juvenile court has a special responsibility to the child as parens patriae and must look to the totality of a child's circumstances when making decisions regarding the child. Accordingly, although both courts focus on the best interests of the child, 'the presumption of parental fitness that underlies custody law in the family court . . . does not apply to dependency cases' decided in the juvenile court. " (Chantal S., supra, 13 Cal.4th at pp. 200-201.) In In re Chantal S., the juvenile court awarded legal and physical custody to the mother, terminated jurisdiction, and made a visitation order that was filed with a family law case number, in part reading as follows: "'Visitation . . . for father . . . to be facilitated by Chantal's therapist, Diane Childs. Before visitation with father and his daughter can occur, father must be: 1. In psychotherapy with a therapist qualified to work with issues such as father's. 2. Father must attend therapy regularly and make satisfactory progress for a time before any visits as determined by his therapist. . . ." (Chantal, supra, 13 Cal.4th at p. 202 The California Supreme Court upheld this order against claims that the juvenile court lacked authority to condition visitation on counseling, and that it had unlawfully delegated visitation authority to the therapists. As for the former claim, the court explained: "As the present case illustrates, however, there are situations in which a juvenile court may reasonably determine that continued supervision of the minor as a dependent child is not necessary for the child's protection, and at the same time conclude that conditions on visitation are necessary to minimize, if not eliminate, the danger that visits might subject the minor to the same risk of physical abuse or emotional harm that previously led to the dependency adjudication." (Chantal, supra, 13 Cal.4th at p. 204.) As for the latter claim, the court held: "Father correctly observes that the order vests some discretion in a therapist of his choice, to determine when 'satisfactory progress' has been made and the ordered visitation may begin. The juvenile court apparently concluded that to protect Chantal, visitation should not begin until father makes sufficient progress in his own therapy. A juvenile court faced with this situation has two options. First, if circumstances warrant, it could deny father visitation, which in effect would require him to later move the family court to amend the order if he wished to secure visitation. . . . Alternatively, the juvenile court could issue the order it did, specifying that visitation commence in a carefully restricted setting when father's chosen therapist determines that father has progressed satisfactorily. "Even assuming arguendo that the order delegated too much judicial discretion, father is not prejudiced thereby. As noted above, father does not contest the position that on this record the juvenile court would have been within its discretion if it simply denied him any visitation. The fact that the juvenile court rejected that course, and instead issued the restrictive order challenged now, amounts to a windfall to father, not a violation of his rights." (Chantal, supra, 13 Cal.4th at pp. 213-214.)