The First Appellate District affirmed orders. The court held that placing a minor boy who was declared a dependent of the court with his presumed father without also removing him from the custody of his mother was not a reasonable alternative to removal that the dependency court should have considered.

A.S. gave birth to Miguel C. in May 2010. In October, the Alameda County Social Services Agency petitioned the dependency court on Miguel’s behalf. The county alleged that A.S. was unable to care for Miguel because of her mental-health and drug-abuse problems. Miguel was detained. Following a contested hearing, the court determined it had jurisdiction.