In re S.N.

In September 2015, the Trinity County Department of Health and Human Services (Department) filed a juvenile dependency petition as to then eight-year-old S.N. The petition alleged that mother "failed to protect [S.N.] in that she drove under the influence of alcohol with [S.N.] in the vehicle, resulting in a single car collision into the embankment, causing [S.N.] to suffer serious physical and emotional harm." The petition further alleged that mother "failed to provide [S.N.] with adequate medical care in that [S.N.] had ligature marks and abrasions on her chest as a result of a vehicle accident which were not immediately treated due to the mother telling [S.N.] she was not 'hurt enough' to require medical care." C.N., mother of minor S.N., appealed the juvenile court’s orders taking jurisdiction and later terminating jurisdiction after awarding custody to father at disposition. She contended the court failed to obtain a valid waiver of her right to a contested jurisdictional hearing. Mother further contended that trial counsel rendered ineffective assistance of counsel at the jurisdictional hearing. In the published portion of the Court of Appeal's opinion, the Court concluded the trial court failed to obtain a valid waiver. Because this error was found as harmless beyond a reasonable doubt, the Court of Appeal affirmed the juvenile court’s orders nevertheless. View "In re S.N." on Justia Law