## Facts

- Alexandra S., mother of 13-year-old Matthew S. and his older sister Sarah S., exhibited longstanding psychotic delusions, including that Matthew’s penis had been mutilated and that she had killed a treating physician in an imagined scenario.
- Acting on these beliefs, Alexandra brought Matthew to a urologist for examination; the physician found no injury, and Matthew denied any injury.
- The physician referred the matter to mental health services due to concern about the effect of Alexandra’s delusions on the children; the county social services department then became involved.
- The department filed a juvenile dependency petition under Welfare and Institutions Code section 300 alleging Matthew was at risk of serious physical and emotional harm and lacked proper support.
- The children described their relationship with Alexandra as warm and wanted to remain with her; Matthew reported he had never felt threatened, but he and Sarah reported being exposed to confusing and implausible statements by their mother.
- After a contested hearing, the juvenile court declared Matthew and Sarah dependents of the court and entered jurisdictional and dispositional orders; Alexandra appealed, mainly challenging the sufficiency of evidence supporting jurisdiction as to Matthew.

## Issues

1. Whether substantial evidence supported dependency jurisdiction under Welfare and Institutions Code section 300 based on a substantial risk that Matthew would suffer serious emotional damage from his mother’s untreated delusions.
2. Whether jurisdiction may be sustained despite the absence of physical injury and despite the children’s expressed affection for, and desire to remain with, their mother.

## Decision

- The Court of Appeal affirmed the juvenile court’s jurisdictional (and related dispositional) orders as to Matthew.
- The court held substantial evidence supported a finding that Matthew faced a substantial risk of serious emotional damage due to Alexandra’s active, untreated delusions and behavior driven by those delusions.
- The court accepted that the statutory basis for jurisdiction may be satisfied by risk of serious emotional harm even without proof of present emotional breakdown or physical abuse.

## Legal Principles

- On appeal from a dependency jurisdictional finding, the reviewing court applies the substantial-evidence standard and defers to the juvenile court’s reasonable factual inferences about risk.
- Dependency jurisdiction under Welfare and Institutions Code section 300 may rest on a substantial risk of serious emotional damage; actual physical harm or a fully manifested emotional injury is not required.
- Parental mental illness, standing alone, is insufficient; jurisdiction requires a demonstrated nexus between the mental condition and a substantial risk of serious harm to the child.
- A child’s expressed affection for a parent and desire to remain in the home does not preclude jurisdiction when evidence supports a substantial risk of serious emotional harm from the parent’s conduct.

## Conclusion

The court affirmed jurisdiction because Alexandra’s persistent, untreated delusions—especially those focused on Matthew’s body and violent imagined events—provided substantial evidence that continued exposure created a substantial risk of serious emotional damage, even though no physical injury was shown and the children reported a loving relationship with their mother.


In re Matthew S., 41 Cal. App. 4th 1311, 49 Cal. Rptr. 2d 139 (Ct. App. 1996)