The Fourth Appellate District granted a petition for writ of mandate. The court held that the record failed to support the dependency court’s finding that the support and reunification services provided to a special needs couple were adequate to facilitate their reunification with their young child.

Nine days after infant T.J. was born, the San Diego County Health and Human Services Agency took him into protective custody and filed a petition alleging that parents Michelle B. and Tracy J. were developmentally disabled and unable to provide regular care to him. The dependency court sustained the petition, removed T.J. from parental custody and ordered a plan of family reunification services.