The Fourth Appellate District affirmed a judgment. In the published portion of its opinion, the court held that where dependency proceedings are initiated based on the acts of the children’s mother, the dependency court is not required to make an express finding of a biological father’s unfitness prior to terminating his parental rights.
The San Diego County Health and Human Services Agency initiated dependency proceedings on behalf of two-year-old A.S. and eight-month-old P.S. when their mother was arrested on drug charges. The children’s alleged father, Joseph S., was not named in the dependency petition.
