Reversed Summary Denials of Section 388 Hearings
In re Daijah T. (2000) 83 Cal.App.4th 666, In re Hashem H. (1996) 45 Cal.App.4th 1791, and In re Jeremy W., supra, 3 Cal.App.4th 1407, are three cases reversing summary denials of section 388 hearings.
The cases are distinguishable.
In Daijah T., the mother had successfully completed her reunification plan and regained custody of three other children. ( In re Daijah T., supra, 83 Cal.App.4th at pp. 673-674.)
In Hashem H., the mother had participated in 18 months of therapy so successfully the therapist recommended that her children be returned. ( In re Hashem H., supra, 45 Cal.App.4th at p. 1799.)
In Jeremy W., the mother had successfully completed all of her reunification plan except for maintaining adequate housing, and her section 388 petition sufficiently alleged a change in that circumstance. ( In re Jeremy W., supra, 3 Cal.App.4th at pp. 1414-1416.)