Department of Human Services v. D. J.

In this juvenile dependency proceeding, father appeals a judgment that changed the permanency plan for his daughter, M, from reunification to adoption.1 Father, who was incarcerated at the time of the permanency hearing, was represented by counsel at the hearing but wished to participate personally and testify by telephone. Father contends that the juvenile court erred in proceeding with the permanency hearing after attempts to call him at the prison failed. We agree and, therefore, reverse.

The facts are not in dispute. In December 2011, father and mother had a violent altercation in M’s…