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In In re Christopher C., No. B216270, the California Court of Appeal for the Second District faced a father's challenge to a court's order placing six of seven children in the care of DCFS and an order of reunification services for the parents that included psychotherapy, counseling, and monitored visitation with the children.
As stated in the decision: "Without objection, the court amended the petition by interlineation to add the following allegation pursuant to subdivisions (b) and (c). 'There exists a severe dysfunction within the family resulting in an ongoing & severe family law conflict, resulting in a cross allegations of sexual abuse, physical abuse, and 'coaching' and there also exists evidence of the failure of the mother and father to properly supervise the children, all of which places the children at risk of serious physical and emotional harm."
Based on the evidence and the family history of DCFS interventions, the court found that there was sufficient evidence to support the juvenile court's jurisdictional findings and also ruled that the father forfeited his claim that an amended petition did not state a cause of action by failing to object at trial.
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