Court of Appeal reversed the juvenile court’s dispositional order bypassing father for reunification services pursuant to WIC section 361.5, subdivision (b)(10) and (11). Application of these bypass provisions required a 2-part analysis: 1) that the parent failed to reunify with a sibling of the child, and 2) the parent subsequently failed to make reasonable efforts to correct the problems leading to the removal of the sibling. The Court agreed with father that there must be an overlap of issues between the current and prior dependency matters when applying section 361.5 (b)(10) and (11) to bypass a parent for reunification services.
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