In In re Rocco M. (1991) 1 Cal.App.4th 814, the juvenile court declared a child a dependent child under section 300, subdivision (b) based upon evidence that, among other things, the child was physically abused by a caretaker on one occasion. Although the appellate court affirmed the juvenile court's jurisdictional order based upon evidence related to the mother's drug abuse, finding the juvenile court reasonably could conclude that the mother's conduct created a substantial risk that the child would ingest drugs, it questioned whether jurisdiction could be based upon the single incident of physical abuse by the caretaker in the absence of evidence that the mother should have anticipated that the caretaker would abuse him or that she would leave the child in the caretaker's care again. (1 Cal.App.4th at p. 825.) The appellate court explained: "While evidence of past conduct may be probative of current conditions, the question under section 300 is whether circumstances at the time of the hearing subject the minor to the defined risk of harm. Thus the past infliction of physical harm by a caretaker, standing alone, does not establish a substantial risk of physical harm; 'there must be some reason to believe the acts may continue in the future.'" (Id. at p. 824.) In In re Rocco M. (1991) the petition had alleged that the mother had left Rocco in the care of a relative who was arrested for possession of heroin and methamphetamines; the mother left Rocco in the care of a friend who kicked him in the stomach; the mother had a history of drug and alcohol abuse that interfered with her ability to provide for and supervise Rocco; and Rocco had previously been removed from the mother's care for three years due to her neglect of his basic needs. (Rocco M., supra, 1 Cal.App.4th at p. 817.) After reviewing the legislative history of a prior iteration of section 300, subdivision (b), the Rocco M. court concluded: "Before courts and agencies can exert jurisdiction under section 300, subdivision (b), there must be evidence indicating that the child is exposed to a substantial risk of serious physical harm or illness" and "while evidence of past conduct may be probative of current conditions, the question under section 300 is whether circumstances at the time of the hearing subject the minor to the defined risk of harm and thus the past infliction of physical harm by a caretaker, standing alone, does not establish a substantial risk of physical harm; 'there must be some reason to believe the acts may continue in the future.'" (1 Cal.App.4th at pp. 823-824.)