In In re Jennifer R. (1993) 14 Cal.App.4th 704, the court of appeal held that the then-existing family law presumption in favor of joint custody as in the best interests of the minor did not apply in juvenile court, because it "has been intimately involved in the protection of the child, and is best situated to make custody determinations based on the best interests of the child without any preferences or presumptions." (In re Jennifer R., supra, 14 Cal.App.4th at p. 712.) The mother challenged the court's grant of sole legal custody to the father, contending that the evidence in the record did not suggest that she should be denied joint legal custody. The court of appeal affirmed, pointing to evidence in the record that the mother was unable to care for herself and her children, did not progress in overcoming the problems that led to removal, and was inconsistent and inappropriate in her visitation, as well as a doctor's report showing emotional disturbance and learning disabilities. (Id. at p. 713.)