The Danger to One Child from Sexual Abuse of Another Child

In In re Joshua J. (1995) 39 Cal.App.4th 984, the Court held that a father who sexually abused a 6-month-old boy reasonably could be found to pose a risk of sexual abuse to the father's newborn son. (Id. at p. 987.) This finding was supported not only by the nature of the abuse, but also by evidence showing that the father suffered from serious mental problems. (Id. at p. 988, fn. 3.) In In re Rubisela E. (2000) 85 Cal.App.4th 177, the Court held that a father who engaged in "sexual abuse on multiple occasions" with his 13-year-old daughter, "including asking the child to orally copulate him," supported a finding that the father posed a risk to his 9-year-old daughter because it was "reasonable for the juvenile court to determine that in the 13-year-old's absence, the father was likely to focus on his only other daughter." (Id. at p. 197.) In In re Karen R. (2001) 95 Cal.App.4th 84, the Court held that "a father who has committed two incidents of forcible incestuous rape of his daughter when she was about 13-years-old reasonably can be said to be so sexually aberrant that both male and female siblings of the victim aged 8 and 6 are at substantial risk of sexual abuse." (Id. at pp. 88-89.) In In re P.A. (2006) 144 Cal.App.4th 1339, the Court held that a father who twice touched his 9-year-old daughter's vagina under her clothes and on top of her underwear reasonably could be found to pose a risk of sexual abuse to the victim's younger brothers who "were approaching the age at which father had begun to abuse his daughter." (Id. at pp. 1345-1348.)