In re Henry V

In In re Henry V. (2004) 119 Cal.App.4th 522, the court found a single incident of physical abuse was insufficient to support a removal order when there was "ample evidence that appropriate services could have been provided to mother and child in the family home. The social worker acknowledged that in-home bonding services were available to assist mother, and that unannounced visits and public health nursing services were potential methods of supervising an in-home placement." (Id. at p. 529.) The social worker recommended an out-of-home placement primarily to obtain the mother's future cooperation with the social worker. (Id. at pp. 529-530.) In Henry V., there was also no indication in the record that either the agency or the juvenile court understood the necessity of making the dispositional findings on clear and convincing evidence. (Id. at p. 530.)