The Court of Appeal agreed that the juvenile court erred when it bypassed reunification services to mother pursuant to 361.5(b)(3). Focusing on the requirement of 361.5(b)(3) that the minor was removed “due to additional physical or sexual abuse,” the Court noted that the juvenile court never made a finding of a new incident of abuse. Instead, the court’s concern was preventing future abuse which was not sufficient to trigger the bypass provision.
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