Riverside County Department of Public Social Services v. Randall S.

Opinion

LUCAS, C. J.

May a juvenile court, when terminating its dependency jurisdiction, issue an order conditioning visitation on a parent’s participation in a counseling program? If so, is the juvenile court bound by the requirements of Family Code section 3190, which governs counseling orders issued by a family court? The Court of Appeal answered these questions “yes” and “no” respectively, thereby creating a conflict with In re Katherine M. (1994) 27 Cal.App.4th 91 [33 Cal.Rptr.2d 298] (Katherine M.). We granted review to resolve the conflict, and affirm.

I. The Distinction Between Juvenile…