In re Edward C.

Edmond and Deborah C. (defendants) were the parents of three children, Eric, Edward, and Marlee. When Marlee was 11 months old, she was adjudicated dependent and placed in the custody of her grandmother, Mrs. C, due to malnutrition and a likely concussion with an unexplained cause. Two years later, Eric and Edward were removed due to lack of food at home and because four-year-old Eric had bruises and welts on his body from Edmond’s severe discipline. The boys were adjudicated dependent and placed in a foster home but were later returned home on a trial basis. Edmond and Deborah would not go to counseling, provided little cooperation, and did not stay in contact with the probation department. The following year, Mrs. C., who had adopted Marlee, allowed Marlee to visit her parents and brothers for two weeks. During this time, Mrs. C. observed Edmond severely disciplining the children. After one beating, Mrs. C. saw blood on Marlee’s underwear, and she called the police, who did a visual inspection, finding abrasions and lacerations on Marlee. Marlee returned to Mrs. C’s custody, and dependency petitions were filed for both boys. At a dependency hearing, Edmond acknowledged that he gave the children spankings but denied causing bruises or even having seen injuries on the children besides bites from insects. Edmond indicated he had disciplined the children according to his faith and that counseling would be of no use. Deborah had already indicated that she was in full support of Edmond’s disciplinary methods. A probation report recommended that Eric and Edward should go to a foster home due to Edmond’s extreme discipline and recommended that Edmond and Deborah attend counseling and work toward appropriate disciplinary methods. After the hearing, a court found that returning Eric and Edward to Edmond and Deborah would be harmful to their welfare and placed the boys in the custody of a probation officer for appropriate placement in foster care or with a relative. The court ordered the parents to undergo counseling. Edmond and Deborah appealed, arguing that the probation report had not recommended a reunification plan as required by law and that they were not informed what was needed to regain custody of Eric and Edward.