In re Precious D.

Precious D. (defendant) was an incorrigible 17-year-old girl who constantly ran away, skipped classes, misbehaved, and hung out with older guys. Due to her behavior, Precious was eventually picked up by police and referred to the Los Angeles Department of Children and Family Services (the department). Precious made allegations for which there was no evidence, such as that her stepfather physically abused her. Precious’s mother, Patricia D., stepfather, and half-sisters denied there had been any physical abuse. Precious also alleged being gang raped, but a medical examination showed no evidence of trauma. Patricia feared that Precious was engaging in prostitution. Precious was placed in two foster homes, but her behavior did not improve while in the foster homes, even with counseling. Precious was later placed in a group home. Throughout these placements, Precious refused to return home to Patricia. However, the department noted that Precious and Patricia continued to speak daily by phone. The department filed a dependency petition regarding Precious, alleging in part Patricia’s failure or inability to supervise or protect Precious under § 300(b) of the Welfare and Institutions Code. The department’s subsequent report regarding jurisdiction and disposition noted that Patricia wanted Precious to return home, but that Patricia told the department that she had tried everything and wanted Precious to get the help she needed first. The report noted that the department was seeking the jurisdiction of the juvenile court due to Precious’s incorrigibility and her need for court-ordered services, among other reasons, and noted that Precious and Patricia remained in open communication with each other. Patricia sought dismissal of the petition on the ground that Precious’s incorrigible behavior was not sufficient reason to assert the court’s dependency jurisdiction. The juvenile court refused to dismiss the petition, citing Precious’s behavior and Patricia’s inability to supervise or protect Precious because the two were not communicating. Regarding disposition, the court removed Precious from Patricia’s custody. Patricia appealed the court’s orders regarding jurisdiction and disposition.