In In re V.F. (2007) 157 Cal.App.4th 962, an incarcerated noncustodial father challenged the juvenile court's order removing the child from the custodial parent under section 361, subdivision (c) without first making findings as to him, the noncustodial parent, under section 361.2. (V.F., supra, 157 Cal.App.4th at p. 969.) At the jurisdiction hearing, the juvenile court sustained section 300, subdivision (b) allegations against the mother. (Id. at p. 967.) At the disposition hearing, the juvenile court removed the children from parental custody under section 361, subdivision (c), granted family reunification services to the mother, but denied family reunification services to the father under section 361.5, subdivisions (b)(12) and (e)(1). (Ibid.) On appeal, the court determined that, when the juvenile court removes a child from a custodial parent, it must then proceed under section 361.2. (V.F., supra, 157 Cal.App.4th at p. 971.) That section "governs the child's temporary placement with the noncustodial parent and the provision of reunification services to the parents, and also permits the court to grant legal and physical custody of the child to the noncustodial parent." (Id. at p. 969.) Moreover, although the father did not make an explicit request for custody before the juvenile court, the court did not find that fatal to his appeal. Rather, the court assumed, without deciding, that father's request for placement of the child with a relative was an "adequate request for custody." (Id. at pp. 971-972.) The V.F. court also rejected the Department's argument, made here as well, that it was unnecessary to remand the case to the juvenile court for a finding of detriment under section 361.2 because the juvenile court had considered and found detriment under section 361.5. (V.F., supra, 157 Cal.App.4th at p. 973.) The court explained that, "when the proceedings take place under an inappropriate statute, even one requiring similar findings, the parties are not afforded the opportunity to tailor their case to the correct statute, and the trial court cannot fulfill its responsibility to make findings of fact within the provisions of that statute." (Ibid.) The court reversed the dispositional orders as to the father and ordered the juvenile court to consider and make findings under section 361.2. (Id. at p. 974.)