"[W]hen a petition contains allegations of an emergency situation, it is proper for a court to issue an interim custody order to protect the child pending a hearing." ( People v. Beach, supra, 194 Cal.App.3d at p. 970; In re Joseph D. (1993) 19 Cal.App.4th 678, 688-689.) No party contends the court did not have the authority at the detention hearing to enter an order temporarily detaining C. with Leslie.

“When a petition contains allegations of an emergency situation, a court may properly issue an interim custody order to protect the child pending a hearing.” (In re Joseph D., supra, 19 Cal.App.4th 678, 688–689, 23 Cal.Rptr.2d 574.) The possibility that the allegations of immediate harm might be true [is] sufficient for the juvenile court to assume emergency jurisdiction under the UCCJA. (Id., at p. 688, 23 Cal.Rptr.2d 574.

The courts have interpreted "emergency" as a situation in which a child is in immediate risk of danger if returned to a parent's care. (See In re Stephanie M., supra, 7 Cal.4th 295 [court asserted emergency jurisdiction over an abused child diagnosed from suffering from battered child syndrome]; In re Joseph D. (1993) 19 Cal.App.4th 678 [emergency jurisdiction was proper based on reported incidents involving sexual abuse by child's stepbrother and father].) Aside from the necessity of protecting a child from immediate harm, presence of the child in the state is the only prerequisite.

States have a parens patriae duty to children within their borders, and the possibility that allegations of immediate harm might be true is sufficient for a court to assume temporary emergency jurisdiction in the best interests of the child under the UCCJEA. In re Nada R., 108 Cal.Rptr.2d 493, 500 (Ct.App. 2001); In re Joseph D., 23 Cal.Rptr.2d 574, 580 (Ct.App. 1993) (quoting Hache v. Riley, 451 A.2d 971, 975 (N.J.Super.Ct. 1982)). The duty of states to recognize and enforce a custody determination of another state must yield if circumstances require temporary emergency orders to protect the child.

"The courts have interpreted 'emergency' as a situation in which a child is in immediate risk of danger if returned to a parent's care. (See In re Stephanie M. [(1994)] 7 Cal.4th 295 [court asserted emergency jurisdiction over an abused child diagnosed as suffering from battered child syndrome]; In re Joseph D. (1993) 19 Cal.App.4th 678 [emergency jurisdiction was proper based on reported incidents involving sexual abuse by child's stepbrother and father].) Aside from the necessity of protecting a child from immediate harm, presence of the child in the state is the only prerequisite.

“The courts have interpreted ‘emergency’ as a situation in which a child is in immediate risk of danger if returned to a parent’s care. (See In re Stephanie M. [(1994)] 7 Cal.4th 295 [court asserted emergency jurisdiction over an abused child diagnosed as suffering from battered child syndrome]; In re Joseph D. (1993) 19 Cal.App.4th 678 [23 Cal.Rptr.2d 574] [emergency jurisdiction was proper based on reported incidents involving sexual abuse by child’s stepbrother and father].) Aside from the necessity of protecting a child from immediate harm, presence of the child in the state is the only prerequisite.

(Fam. Code, § 3403, subd. (a)(4).) After briefing concluded, mother referred us to the recent decision of the Court of Appeal in In re Joseph D. (1993) 19 Cal.App.4th 678 [ 23 Cal.Rptr.2d 574] for the proposition that a juvenile court asserting emergency jurisdiction cannot enter jurisdictional or dispositional orders without contacting the jurisdiction where the child had been most recently residing. The case is inapposite; there the California juvenile court was aware that a sister state custody order was in effect and nonetheless improperly asserted continuing concurrent jurisdiction to determine the child's custody.

It appears that the California line of cases originates from a 1993 decision under the uniform act that preceded the UCCJEA. See In re Joseph D. , 19 Cal. App. 4th 678, 23 Cal. Rptr. 2d 574 (1993). In that case, the court concluded that the lower court had erred in continuing emergency jurisdiction and proceeding with a dispositional hearing in a dependency matter where there was a previous child custody determination from Pennsylvania.

"The courts have interpreted 'emergency' as a situation in which a child is in immediate risk of danger if returned to a parent's care. (See In re Stephanie M. [(1994)] 7 Cal.4th 295 [court asserted emergency jurisdiction over an abused child diagnosed as suffering from battered child syndrome]; In re Joseph D. (1993) 19 Cal.App.4th 678 [emergency jurisdiction was proper based on reported incidents involving sexual abuse by child's stepbrother and father].) Aside from the necessity of protecting a child from immediate harm, presence of the child in the state is the only prerequisite.

" ( Id. at pp. 108-109.) The appellate court in C.T. distinguishes this approach from the solution previously set forth by a panel of the same court in In re Joseph D. (1993) 19 Cal.App.4th 678 [ 23 Cal.Rptr.2d 574] ( Joseph D.). The Joseph D. court concluded that the juvenile court in that case should have contacted the other state's court after it had sustained the section 300 petition and made its jurisdictional finding, but before it proceeded with the dispositional hearing. ( Joseph D. at p. 691.)