The Fourth Appellate District affirmed a judgment. The court held that a finding of current risk of harm is not necessary to a determination that a minor is a dependent of the juvenile court under Welf. & Inst. Code §300(f) on the ground that the minor’s parent caused the death of another child through abuse or neglect.
D.M. and Tiffany were the parents of James and his four siblings, A.M., Anastasia M., Gage M., and Gavin M. Newborn James died in 2004. D.M. and Tiffany were referred to the San Diego County Health and Human Services Agency (county). They agreed to participate in therapy and evaluations to address their grief. The county also recommended that A.M. receive therapy.
