Alameda Cnty. Soc. Servs. Agency v. Alberto C. (In Re I.C.)

*714 *875 In a juvenile dependency proceeding, a child's out-of-court reports of parental abuse are admissible in evidence regardless of whether the child is competent to testify in court. ( In re Cindy L. (1997) 17 Cal.4th 15 , 20, 69 Cal.Rptr.2d 803 , 947 P.2d 1340 ( Cindy L. ); Welf. & Inst. Code, § 355.) But a juvenile court may not base its findings solely on the hearsay statements of a truth-incompetent child-that is, a child who may not testify because she is too young to separate truth from falsehood-unless the child's statements bear "special indicia of reliability." ( In re Lucero L. (2000)…