Department of Human Services v. J. C. S.

In July 2015, the juvenile court asserted jurisdiction over child, S, after concluding that father, who was incarcerated, was unavailable as a custodial resource for child.1 Shortly thereafter, the Department of Human Services (DHS) filed a new dependency petition alleging an additional basis for jurisdiction related to father’s domestic violence. In April 2016, the court asserted jurisdiction over S based on the new allegation.

On appeal, father challenges the 2016 jurisdictional judgment, arguing that the court erred in asserting jurisdiction over S in the absence of expert testimony that…