November 24, 2015
In a writ petition challenging the juvenile court's denial of reunification services to D.F. under Welfare and Institutions Code section 361.5, subdivision (b)(11), the court distinguished subdivision (b)(11) from subdivision (b)(10) and Melissa R. v. Superior Court, 207 Cal. App.4th 816 (2012), to hold that the plain language of (b)(11) allows for the bypass of reunification services when termination of services and removal as to a sibling have occurred outside of California.
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