In re Gloria L. CA1/4 filed 6/22/26

Filed 6/22/26 In re Gloria L. CA1/4
NOT TO BE PUBLISHED IN OFFICIAL REPORTS
California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA
FIRST APPELLATE DISTRICT
DIVISION FOUR

In reGloria L., a Person Coming Under the Juvenile Court Law.

SAN FRANCISCO HUMAN SERVICES AGENCY,
Plaintiff and Respondent,
v.
E.B.,
Defendantand Appellant.
A174994
(San Francisco City &County Super. Ct.No. JD253196)

E.B.(Mother), the mother of Gloria L.,seeks reversal of a dependency courtorder asserting jurisdiction over Gloria in a Welfare and Institutions Code section 300 proceeding based on afinding that Mother’s substance abuse issues created a substantial risk of harm to Gloria. Mother argues there is insufficient evidence to support the court’s finding. We disagree and will affirm.
BACKGROUND
In August 2025, the Agency filed a petition seeking to detain 22-month-old Gloria from Mother (then 40 years old) and Gloria’s father(Father)based on a number of section 300allegations. This included an allegation, made under section 300, subdivision (b)(1),that Gloria had suffered or was in substantial risk of suffering serious physical harm or illness as a result of Mother’s substance abuse issues. The Agency alleged “Mother has substance abuse issues for which she requires assessment and treatment and which impedes her ability to provide adequate care, protection, and supervision of the 1 year old child. Child welfare history indicate that the mother has a history of abusing methamphetamines and used methamphetamines while she was pregnant with her older child [M.P.] (DOB 01/2017). The mother has a criminal record including convictions for drug related charges.” Because the juvenile court sustained only thissubstance abuse allegation against Mother, we will focus our attention on it.
At the jurisdiction hearing, the juvenile court considered the Agency’s detention report, jurisdiction/disposition report and addendum, as well as some witness testimony.
Detention Report
According to the detention report, the Agency received a report on August 4, 2025 about Mother’s and Father’sgeneral neglect of Gloria. The reporting party “stated that the father contacted the paternal aunt . . . who is in Georgia for help retrieving [Gloria], stating that the father and the mother were on drugs, and he had no money and ‘it was too much’. [The paternal aunt] arranged for a paternal family friend . . . to pick up [Gloria]. [Gloria] was reportedly found with extremely wet diaper, unwashed hair and hungry, with no injuries or bruises.” Father’s home reportedly “smell[ed] of smoke with the presence of drug paraphernalia, i.e., pipes, ‘white stuff’, THC, had a broken door and was in disarray.”There were “clothes, a baby mattress, and garbage scattered on the floor . . . .” The reporting party told the Agency of the concern that “if the parents continue to abuse illicit substances that [Gloria] could gain access to unsecure illicit substances, or immediate needs for care will be neglected.” The paternal family friend reported not knowing the whereabouts of the mother when she picked up Gloria.
The Agency wrote that two protective services workers went to Father’s home in the late afternoon of the day of the report, August 4, 2025, and also called him. After initially answering his phone,Father would not communicate with them or allow them into his apartment. The workers observed that the apartment door was damaged and patched with duct tape. On it was an August 1, 2025 notice stating that Father had violated the terms of his tenancy when,six days earlier, his visitor—apparentlyMother (the notice listed a name the same as hers except for an additional letter in the surname)—allowed another visitor to enter the property.
On this August 4, 2025 visit to Father’s apartment, one of the protective servicesworkers spoke with the property manager who, asked if Father was known to use substances at home, replied, “ ‘It is not shocking to me.’ ” The manager said Mother and Father “were known to have verbal altercations in front of [Gloria] and that they ‘messed around’ and created ‘bad scenes’ . . . at father’s home.” Police records regarding Father’s address showed four incidents classified as a “ ‘fight or dispute’ ” from November 2024 to August 2025, with aMarch 2025 note referring to domestic violence.
That evening, the protective services workers located Gloria at the paternal family friend’s home. The friend said that after Father contacted the paternal aunt that morning about caring for Gloria, the paternal aunt contacted the friend,who took Gloria to her home. Because a child Gloria’s age “is highly mobile, curious and unaware of danger, making her vulnerable to accidental ingestion, injury or exposure to toxic substances[,]” the Agency detained her at that point.
On the evening of Gloria’s detention, Mother called the Agency and “stated she had gone to the father’s residence in the morning because ‘the minor missed the father.’ The mother reported that she left the residence to buy toilet paper, but the father did not let her back in afterwards. The mother said she had called 911 for assistance but did not know the incident report number.”
Later that evening, Mothervoluntarily met with a protective services worker but indicated she would only speak about matters in the presence of her attorney. According to the detention report, whenthe protective services worker referred to Mother’s violation of a restraining orderagainst Father, Mother responded, “ ‘But it was filed by me,’ and reiterated her earlier statement that she had only gone to the father’s apartment that morning because the minor missed him. [She] denied being at the father’s residence prior to August 4, 2025.”
The Agency confirmed that a restraining order against Father was in place until November 2027 that prohibitedhim from having any contact with or proximity to Mother, Gloria, or the maternal grandparent. Mother had sole legal and physical custody of Gloria, and, by the terms of the restraining order, Father was to “have no visitation or contact with the child until further order of the court.”
Mother said she did not understand the detentiondecision and that after she went to buy toilet paper Father would not allow her back in his apartment. She showed the protective services worker a record of a 911 call she had made at 11:08 that morning, said she did not know if an officer had followed up, and stated that she was sober and willing to take a drug test. The Agency confirmed with the police that a call was received at the time Mother had indicated, logged as involving a “ ‘fight or dispute,’ ” and that it had been unable to obtain any incident report.
The morning after their initial visit, the protective services workers returned to Father’s apartment. As they waited for him (he did not appear despite indicating he was on his way), Mother appeared. That afternoon, Mother completed a drug test, which the Agency later reported was negative. Mother also agreed to call the testing center every day and participate in random tests over the next 90 days.
The Agency’s records indicated a Child Protective Services referral had been received the previous November involving “an allegation of general neglect against both the mother and the father . . . due to a documented pattern of domestic violence in the household, which posed a safety concern and imminent risk of serious harm to [Gloria].” “[T]he father reportedly sent threatening messages to the mother, including death threats, and violated a protective order by appearing unannounced at the mother’s residence on November 16, 2024. The referral was closed on Jan 02, 2025, in the consideration of the mother taking protective measures, including obtaining full custody, securing an extension of the restarting [sic] order, arranging alternative housing and ensuring the father was banned from the premises.”
The Agency also summarized Mother’s extensive history with child welfare agencies. Between 2017 and 2023 there were six referrals, one of which was substantiated, reporting her use or possession of methamphetamine or related paraphernalia, including use while pregnant and while breastfeeding, that impaired her ability to care for children (other than Gloria). There were two referrals in 2024 regarding Father’s substance abuse or domestic violence, including a November 2024 substantiated referral that was discontinued after Mother obtained full custody of Gloria and a restraining order against Father.
The Agency further reported that Mother had seven criminal convictions between 2003 and 2021 involving theft-related and/or substance-related crimes. These convictions included driving under the influence (2003); possession of a controlled substance and paraphernalia (2005); possession of a controlled substance (2013); and possession of a controlled substance (2014). Also, in December 2023, Mother reportedly was arrested after she was found to possess a glass pipe used for smoking narcotics and suspected crystal methamphetamine.
Jurisdiction/Disposition Report
In a jurisdiction/disposition report the Agency filed with the court in September 2025, itreported additional information regarding Mother. This included that she told the Agency in August 2025 that Father had reported her drug use to his paternal aunt because he was “ ‘trying to play games,’ ” that he used Gloria as a “bargaining tool,” and that there was “no way that anyone saw paraphernalia or ‘white stuff’ in the apartment . . . .” She also said she thought paternal aunt had made up that Father had admitted to using drugs. Shesaid that “Gloria was never in the presence of any altercations between herself and [Father].” She acknowledged she should not have been at Father’s residence, but said she was there because she was upset that he reportedly was back with hisex-girlfriend. She also said she and Father had to live elsewhere at some point so the door to his apartment could be fixed, and that “the door issue was not true.”
As for Mother’s substance use,Mother told the Agency that “she has never gotten high around her children and that she always made sure that her children were with safe adults, such as her parents, before she would use.” She acknowledged using at the beginning of her pregnancy with another, older child, and said she stopped immediately when she found out she was pregnant. She said that “prior to ceasing use, her drug of choice was methamphetamine, while [Father’s] was powdered heroin, which he used by snorting.” She identified her main addictions as alcohol, which she had started to use at age 15, and methamphetamines, which she had started to use at age 21. She also said she had a sponsor. The Agency also reported that during a 2017 voluntary family maintenance case, Mother had tested negative for substances six times and missed two tests.
Father told the Agency that he was a recovering addict and denied currently using substances. He agreed to begin substance use testing. Mother said Father was no longer using substances and she did not believe his past use affected his ability to adequately parent Gloria.
In September 2025, Mother reported to the Agency that she had begun to see a therapist weekly. A substance treatment program reported that Mother had recently completed an intake with the program and was going to begin weekly individual substance use counseling. Although she had previously minimized Father’s domestic violence in comments to the Agency, she saw a lawyer in September 2025 to begin the process of divorcing Father (later confirmed by an Agency worker).
The Agency further reported that Mother had tested negative for substance use five times—three in August 2025 and two in September 2025. She had not shown up for 10 tests—six in August 2025 and four in September 2025. She had given the Agency explanations for three of her no-shows, and the Agency had not yet discussed the other seven with her.
According to the Agency, Mother initially denied having any Child Protective Services history with her previous children. But the Agency found in a search of a child welfare database that Mother’s history showed nine referrals and three cases. Her first two children both had voluntary cases open that closed due to lack of participation in services by the parents. She also told the Agency that she had two active criminal cases, including one in San Mateo County “for driving on a suspended license and someone had left paraphernalia in her car.”
After Gloria was detained, Mother was allowed twice-weekly, three-hour supervised visits with her. The Agency reported that Mother “was consistent with these visits in August [2025], but has since missed three visits in September . . . . [Mother] did not give any advanced notice of cancellation for any of these visits.” She told the Agency she had overslept for two visits and missed another due to an emergency medical issue. Mother acted appropriately and Gloria was happy and comfortable in her presence during the visits that did take place.
The Agency wrote that it had “significant concerns” about Mother’s ability to care for Gloria in light of her history of substance abuse, domestic violence, prior child welfare involvement, and missed tests and visits. It recommended court intervention, placement of Gloria away from the parents, and reunification services.
The Addendum Report
In an addendum report filed in October 2025, the Agency reported that Mother had not shown up for four additional drug tests, bringing thenumberof her missed drug tests up to fourteen. She had not been tested for about six weeks. Also, she had failed to complete a court-ordered hair follicle test. She had missed several recent visits with Gloria, including two in October. She was admitted to the hospital in one instance and had planned to use a car that would not start in the other.
The Court’s Assertion of Jurisdiction
The dependency court commenced the contested jurisdiction/disposition hearing on November 20, 2025. Among other things, the court admitted into evidence the Agency’s detention, jurisdiction/disposition, and addendum reports. Prior to the hearing, Mother filed objections under section 355 to various parts of the Agency’s reports. At the conclusion of the hearing, the court said it had “carefully considered” the section 355 objections, and that its ruling was “based only on admissible evidence.”
Testimony of Agency Protective Services Worker Hermia Lee
Agency protective services worker Hermia Lee testified that she wrote the detention report. Among other things, she said that she had received the referral regarding Gloria on August 4, 2025, and immediatelyinvestigated. That day, she went to Father’s apartment but did not go inside it. The reporting party (who did not want to testify at the hearing according to the other testifying protective services worker)was the paternal family friend Lee hadreferred to in her report. The reporting party was the source of the information about Father’s apartment’s condition contained in the report.
Lee further testified that when she spoke with Mother by phone the night of Lee’s visit to Father’s apartment, shewas not sure if Mother was under the influence of substances becauseshe was crying. They met later that evening andLee did not suspect Mother was under the influence at that time. As we have recounted, Mother agreed to be drugtested, and tested negative for any substances the next day.
Testimony of Agency Protective Services Worker Joshua Coy
Agency protective services worker Joshua Coytestified that he wrote both the jurisdiction/disposition report and the addendum. Since he had written the addendum report, Mother had not engaged in any servicesthat he knew about. She had not tested for substancesor participated in the court-ordered hair follicle test.
Coy further testified that since he wrote the addendum report, Mother had missed three more visits with Gloria. He had confirmed Mother was in the hospital on twoof those occasions. Mother attended one visit with Gloria, which went positively, but she left early because she was not feeling well. She said she had started working at UPS and asked for visits on the weekend, but the Agency could not accommodate her request.
Coy testified that he had met with Mother about four times and talked with her by phone 20 to 25 times. Asked if Mother always appeared “sober” in their interactions, he said, “I would say in person, yes. On the phone, it is hard to tell. It is—you know, she is just waking up, and she is groggy, so it is hard to tell.” He had never seen her use any substances and, in his two visits to her apartment, had not seen any drugs or paraphernalia.
Coy also testifiedthat in November 2024, both a civil restraining order and a criminal protective order were issued against Father. Coy understood the orders had been issued based on Father sending threatening messages to Mother. Coy was not aware of any threats by Father against Gloria and had not seen any signs of abuse or trauma on Gloria.
Coy confirmed his recommendation was that the court order that Gloria was a dependentof the court whowould remain in out-of-home care whilethe parents were provided with reunification services. Hecited as support for his recommendation that neither parent had engaged in the recommended services, bothparents were not testing, and both lacked engagement.
The Court’s Ruling
Most of the Agency’s petition allegations regarding Mother were either dismissed by the Agency or struck by the dependency court. The only one that remained for the court’s consideration was that Mother had substance abuse issues that required assessment and treatment and impaired her ability to care for Gloria, and had a history of drug use and drug-related criminal convictions. The court sustained that allegation by a preponderance of the evidence. It cited as support for its conclusion Mother’s documented drug history and her prior drug-related dependency case and 2023 criminal conviction. Further, Mother had missed the majority of her drug tests, offered excuses and rationales the Court did not find credible for doing so, and requested thecourt-ordered hair follicle test but did not take it.
The court continued: “I find her explanation of sobriety after decades of drug use not credible. Her denial of an issue around drugs coupled with her refusal to test creates a substantial risk of harm for this young and vulnerable child.
“It is undisputed that she left the child with [Father] in violation of the restraining order, and that evidence and the reasonable inferences therefrom demonstrate by a preponderance of the evidence that she is unable to make protective decisions. She is willing to violate a restraining order and leave the child in the care of [Father], a person who was prohibited from seeing the child.
“There is in this Court’s view sufficient evidence of causation and sufficient evidence of a nexus. The Court is not presuming from [Mother]’s prior drug use that she cannot care for the child. To the contrary, the Court is considering from all of the evidence presented that [Mother]’s substance useposes a substantial risk of current harm to the child.”
The court placed Gloria with Motherwith family maintenance services. Mother filed both a timely notice of appeal and a timely amended notice of appeal.
DISCUSSIOn
Mother argues that this appeal “presents a narrow but consequential question: whether a parent’s distant history of substance use, coupled with voluntary but imperfect pre-jurisdiction compliance, can substitute for proof of a present, nonspeculative risk of serious harm to a child.” She contends the court erred in findingshe had substance abuse issues because she “was never observed under the influence, completed five voluntary, random tests that were all negative, consistently demonstrated safe, affectionate parenting during supervised visits, and had no drugs or paraphernalia in her home.”
We are unpersuaded. Motherignores or undervalues a significant amount of evidence and the reasonable inferences to be drawn from that adverse evidence that undercut her arguments. Her appeal amounts to a request that we reweigh evidence the dependency courthas carefully considered. The deferential substantial evidence standard of review is dispositive here. As explained further below, we seeno error and will affirm.
Legal Standards
Section 300, subdivision (b)(1) provides that a court may adjudge a child to be a dependent of the court if, among other things, “[t]he child has suffered, or there is a substantial risk that the child will suffer, serious physical harm or illness, as a result of” a parent’s “inability . . . to provide regular care for the child due to the parent’s . . . substance abuse.” (§ 300, subd. (b)(1)(D).) Thus, a jurisdictional finding under subdivision (b)(1)(D), requires evidence that “(1) substance abuse (2) makes a parent or guardian unable to provide regular care for a child and (3) this inability has caused the child to suffer serious physical harm or illness or creates a substantial risk of such harm or illness.”(In re N.R. (2023) 15 Cal.5th 520, 558.)
“Although section 300 requires proof the child is subject to the defined risk of harm at the time of the jurisdiction hearing [citations], the court need not wait until a child is seriously abused or injured to assume jurisdiction and take steps necessary to protect the child. [Citations.] The court may consider past events in deciding whether a child presently needs the court’s protection. [Citations.] A parent’s ‘ “[p]ast conduct may be probative of current conditions” if there is reason to believe that the conduct will continue.’ [Citations.] ‘To establish a defined risk of harm at the time of the hearing, there “must be some reason beyond mere speculation to believe the alleged conduct will recur.” ’[Citation.]” (In re Cole L. (2021) 70 Cal.App.5th 591, 601–602 (Cole L.).)Further, “the court may . . . consider past events when determining whether a child presently needs the juvenile court’s protection. [Citations.] A parent’s past conduct is a good predictor of future behavior. [Citation.] ‘Facts supporting allegations that a child is one described by section 300 are cumulative.’[Citation.] Thus, the court ‘must consider all the circumstances affecting the child, wherever they occur.’ ” (In re T.V.(2013) 217 Cal.App.4th126, 133.)
“Jurisdictional findings must be made by at least a preponderance of the evidence.” (Cynthia D. v. Superior Court (1993) 5 Cal.4th 242, 248, citing §355.) “Any legally admissible evidence that is relevant to the circumstances or acts that are alleged to bring the minor within the jurisdiction of the juvenile court is admissible and may be received in evidence.” (§ 355, subd. (a).)“A social study prepared by the petitioning agency”which preparer is available for cross-examinationand “hearsay evidence contained in it, is admissible and constitutes competent evidence upon which a finding of jurisdiction pursuant to Section 300 may be based,” except that when a timely objection is made to “the admission of specific hearsay evidence contained in a social study, the specific hearsay evidence shall not be sufficient by itself to support a jurisdictional finding or any ultimate fact upon which a jurisdictional finding is based,” subject to certain exceptions not relevant here. (§ 355, subds. (b)(1)–(2), (c)(1); In re I.C. (2018) 4 Cal.5th 869, 886.)
We review the dependency court’s jurisdictional findings for substantial evidence. (Cole L., supra, 70 Cal.App.5th at p. 602.) Substantial evidence is “evidence which is reasonable, credible, and of solid value . . . .” (People v. Perez (1992) 2 Cal.4th 1117, 1124.) “We do not evaluate the credibility of witnesses, attempt to resolve conflicts in the evidence or determine the weight of the evidence. Instead, we draw all reasonable inferences in support of the findings, view the record favorably to the juvenile court’s order and affirm the order even if there is other evidence supporting a contrary finding.” (In re R.V. (2012) 208 Cal.App.4th 837, 843.) “[T]he inferences ‘“must be ‘a product of logic and reason’ and ‘must rest on the evidence’ [citation]; inferences that are the result of mere speculation or conjecture cannot support a finding [citations].” ’ ” (In re Roxanne B. (2015) 234 Cal.App.4th 916, 920.)“The appellant has the burden of showing there is no evidence of a sufficiently substantial nature to support the findings or order.” (In re R.V., at p. 843.)
Analysis
There is substantial evidence to support the dependency court’s sustaining of the allegation of Mother’s substance abuse issues that is the basis for the court’s assertion of jurisdiction over Gloria.
This case arose when the Agency received a report from a paternal family friend that Father had called his sister in Georgia and told her that he and Mother were doing drugs; that Mother had left Gloria (who wasless than two years old at the time) at Father’s apartment in violation of a restraining order designed to protect Gloria from Father’s domestic violence; that in Father’s apartment, Gloria was exposed to drugs, drug paraphernalia, and garbage strewnabout; and that Gloria herself was badly soiled and hungry.Mother was nowhere to be found. Father would not speak to or allow anyone into his apartment when responding protective service workers arrived.
Late that day, after the Agency detained Gloria, and thereafter,Mother gave the Agency what the dependency court could reasonably conclude weresuspicious, illogical, and false accounts of what occurred. She said Gloria was only at Father’s apartment because Gloria missed Father, a story she later changed to one in whichshewent to the apartment after hearing Father was back together with his ex-girlfriend. She said she left Gloria in Father’s care briefly to buy toilet paper and that Fatherhad not let her back into the apartment, causing her to call the police; but the court could reasonably find this account incredible because it did not explain why Mother was nowhere to be found when the paternal family friend and the Agency workers separately arrived at Father’s apartment later that day, when the family friend took Gloria away, and when the Agency went to the friend’s home and detained her.
Mother also contradicted herself. She denied that she and Father had been using drugs and claimed the reporting party had made up the story.But she also said Father said she was doing drugs because he was “ ‘trying to play games’ ” and used Gloria as a “bargaining tool.”
The court had further reason to doubt Mother’s veracity and parenting ability. It could reasonably conclude that shelied in saying that she (and by inference Gloria) had not been at Father’s apartment prior to August 4, 2025based on a reported notice on the apartment door indicating she had been there a few days before and her observed visit to the apartment the day after Gloria was detained, and even that she had lived with Father, since she told the Agency that she and Father had lived elsewhere while the apartment’s broken door was repaired. The court could also reasonably conclude that Mother showed hazardousparenting judgment when she indicated she could not understand why the Agency was concerned that she had left Gloria with Father in violation of a court order prohibiting contact between them because of his domestic threats. And given the report that Father told his sister the two were doing drugs on August 4, 2025, the court could reasonably conclude Mother’s negligent exposure of Gloria to Father was related to her substance abuse issues.
There is also substantial evidence that Mother has a significant history of substance abuse and related criminal activity and history with child welfare agencies that the court could reasonably rely on toconclude she continued to have substance abuse issues. (See Cole L., supra, 70 Cal.App.5th at p. 602.) Between 2017 and 2023 there were six referrals related to Mother’s substance abuse, including abuse while caring for young children. She had drug-related convictions between 2003 and 2014, a theft-related conviction in 2021, and in December 2023—only about a year and a half before Gloria was detained—Mother reportedly was arrested after she was found to possess a glass pipe used for smoking narcotics and suspected crystal methamphetamine. Mother also lied to the Agency about her extensive child welfare history, temporarily concealing reports of her prior drug-related neglect of her children by doing so.
The record also contains direct indications that Mother had not resolved her substance abuse issues and put them in the past. Along with the report that Father said she was actively using drugs, Mother eventually disclosed to the Agency that she had a pending criminal case that—by her own account—involved someone leaving paraphernalia in her car. In light of Mother’s repeated dissembling and substance abuse history, the court could reasonably conclude she was again facing legal trouble because of an alleged personal involvement with illicit drugs.
Mother’s framing of the issue presented here as one involving a jurisdictional finding based on her past drug history is overdrawn. Among other things, the court also relied on her violation of the restraining order—which itself is substantial evidence that Mother had endangered Gloria because of her substance abuse issues—in evaluating the significance of Mother’s numerous missed drug tests and visits with Gloria.
The totality of the evidence can also be reasonably read to further indicate that Mother’s drug involvement is not truly in the past. While she tested negatively five times in August and September 2025, she missed fourteen tests, as well asacourt-ordered hair follicle test that she apparently requested, and she offered no excuse for most of her absences. Motheralso missed a number of visits with Gloria (other than those that were scheduled at a time when she was hospitalized), asserting for two of them that she had merely overslept. The Agency workers never saw Mother under the influence, but reported that she at times on the phone sounded groggy, like she was just waking up.
Given the sum total of all of this evidence, the court fairly inferred that Mother continued to struggle with substance abuse andthat, as a result, Gloria was at serious risk of harm.(See In re Natalie A. (2015) 243 Cal.App.4th 178, 186 [reasonable to infer from a father’s failure to show for all but one prejurisdiction voluntary drug test that his drug use was more frequent than his admitted one instance, an inference bolstered by his past substance abuse and failure to complete a drug treatment program]; In re E.E. (2020) 49 Cal.App.5th 195, 213–215 [court, in rejecting a mother’s claim of a lack of evidence that she was a substances abuser, affirmed jurisdiction finding over siblings, noting the mother’s past drug use, dishonesty about her past use, resistance to treatment, and several missed drug tests]; In re Lana S. (2012) 207 Cal.App.4th 94[court, in finding substantial evidence supported a jurisdictional finding, citing areport by a third party to the human services agency that a mother had used methamphetamines and a police report that drug paraphernalia was found in her home within reach of the children].)
Arguing to the contrary, Mother insists that, while she had a substance abuse history dating back two years before the filing of this case, “there was nothing in the present to indicate she was abusing substances” or evidence of any “identified risk to [Gloria] based on Mother’s behavior or conduct.” She further contends that “[h]er care of her daughter was stellar and there were no events during this case that showed she was unable to provide care for her daughter.” She relies heavily on case law that mere drug use, or even abuse, is insufficient to support a jurisdictional finding(see, e.g.,In re Gilberto G. (2024) 105 Cal.App.5th 52, 67; In re Rebecca C. (2014) 228 Cal.App.4th 720, 727–728), and her own account of events. These contentions and case law are unpersuasive because of the substantial evidence we have already summarized, upon which the dependency court could reasonably rely to reject Mother’s contentions.
Mother further argues that “missed, voluntary, pre-jurisdiction tests should not be given adverse inference under the particular factual circumstances of this case where there were five negative drug tests,” and that her due process rights were violated because she did not receive notice that her agreement to test would later be used against her in jurisdiction proceedings. But she has waived these arguments by her failure to cite supporting legal authority for them. (In re A.C. (2017) 13 Cal.App.5th 661, 672 [“ ‘When an appellant . . . fails to support [a point] with reasoned argument and citations to authority, we treat the point as waived.’”].)
We see no reason why the court could not make reasonable inferences from Mother’s unexplained testing absences. She agreed to take drug tests and, although shetested negative five times, she failed to appear for most of thetests—fourteen of them—often without explanation; and at the time of the jurisdiction hearing, she had not tested for many weeks. She also failed to take a hair follicle test that she apparently requested and that the court ordered. It is common sense to infer from these circumstances that Mother feared being tested because of substance abuse issues. (See In re Kadence P. (2015) 241 Cal.App.4th 1376, 1384 [noting that “a missed drug test, without adequate justification, is ‘properly considered the equivalent of a positive test result’ ”], disapproved on other grounds in In re N.R., supra, 15 Cal.5th at p.560, superseded by statute on other grounds as stated in In re A.M. (2020) 47Cal.App.5th 303, 322 [disapproved in part on other grounds in In re Dezi C. (2024) 16 Cal.5th 1112, 1151–1152].)
DISPOSITION
The order appealed from is affirmed.
STREETER, J.
WE CONCUR:
BROWN, P. J.
SWEET, J.*