"Section 362.4 governs the termination of juvenile court jurisdiction and related orders." (In re J.M. (2023) 89 Cal.App.5th 95, 112 (J.M.).) "The statute authorizes a juvenile court to make 'exit orders' regarding custody and visitation upon terminating dependency jurisdiction over a child."
(See id., at pp. 1112, 1121-1122 &fn. 9 [concluding the father did not forfeit the contention that the trial court erred in failing to ensure his daughter was able to visit her half-brother because, although the father did not raise the issue, it was nevertheless raised in the juvenile court by the paternal grandmother who was a de facto parent].) Father contends the juvenile court had that opportunity because the children's attorney herself raised the issue when, at the January 25, 2024 hearing, she mentioned In re J.M. (2023) 89 Cal.App.5th 95. In that case, our colleagues in Division Four of this court concluded that, although section 361 findings are required at the disposition stage of dependency proceedings, they do not apply to subsequent custody and visitation orders upon termination of jurisdiction issued at a section 364 review hearing under section 362.4.
In fact, "Section 362.4 does not require a finding of detriment under any circumstances." (In re J.M. (2023) 89 Cal.App.5th 95, 113 (J.M.).)
"Section 362.4 governs the termination of juvenile court jurisdiction and related orders." (In re J.M. (2023) 89 Cal.App.5th 95, 112 (J.M.).) "The statute authorizes a juvenile court to make 'exit orders' regarding custody and visitation upon terminating dependency jurisdiction over a child."
The statute authorizes a juvenile court to make 'exit orders' regarding custody and visitation upon terminating dependency jurisdiction over a child." (In re J.M. (2023) 89 Cal.App.5th 95, 112 (J.M.), citing § 362.4, subd. (a); In re Chantal S. (1996) 13 Cal.4th 196, 202-203 (Chantal S.).) "These exit orders remain in effect until modified or terminated by a subsequent order of the superior court." (J.M., at p. 112, citing § 362.4, subd. (b); see also Cal. Rules of Court, rule 5.700(a).
The statute authorizes a juvenile court to make 'exit orders' regarding custody and visitation upon terminating dependency jurisdiction over a child." (In re J.M. (2023) 89 Cal.App.5th 95, 112 (J.M.), citing § 362.4, subd. (a); In re Chantal S. (1996) 13 Cal.4th 196, 202-203 (Chantal S.).) "These exit orders remain in effect until modified or terminated by a subsequent order of the superior court." (J.M., at p. 112, citing § 362.4, subd. (b); see also Cal. Rules of Court, rule 5.700(a).)
[Citations.]" (In re J.M. (2023) 89 Cal.App.5th 95, 112.) II. Standard of Review
Because she had the burden of proof below to show that continued jurisdiction was necessary and failed to meet that burden, to demonstrate error on appeal she must show that as a matter of law, the evidence compelled a finding in her favor. (In re J.M. (2023) 89 Cal.App.5th 95, 111.) She has failed to make that showing.
(T.S., at p. 514; see In re J.M. (2023) 89 Cal.App.5th 95, 112 [in making a custody and visitation order "'the juvenile court must look at the best interests of the child'"].) "'[T]he juvenile court has broad discretion to make custody [and visitation] orders when it terminates jurisdiction in a dependency case.'"
The statute authorizes a juvenile court to make "exit orders" regarding custody and visitation when it terminates dependency jurisdiction over a child. (§ 362.4, subd. (a); In re Chantal S. (1996) 13 Cal.4th 196, 203; In re J.M. (2023) 89 Cal.App.5th 95, 113.) These exit orders remain in effect until modified or terminated by a subsequent order of the superior court.