The juvenile court ordered family maintenance services for the mother and family reunification services for the father, and ordered both parents to attend parenting education classes.

During an argument, the father punched his adult stepdaughter in the face and broke her nose. When his 15-year-old daughter intervened to protect her sister, the father hit her three times, slapped her repeatedly, and pulled her hair. He also pushed a five-year-old niece. At some point during the altercation, the mother intervened, restrained her husband, and directed someone to call the police. Father surrendered to the police and was arrested (and later charged) with assault with a deadly weapon. The Department of Children and Family Services (the department) initiated section 300 proceedings regarding the three siblings. The children were released to their mother, and the court found that it was not in their best interests to live with their father. At the next hearing, the department reported that the children appeared happy with their mother and were safe as long as the father did not reside in the home. The social worker recommended parenting classes for both parents. The court scheduled an adjudication and contested hearing. At the hearing, both the mother and father personally waived their rights and submitted on the social worker's report. The juvenile court found jurisdiction under section 300, placed the children in the home of the mother, and ordered family maintenance services for the mother and family reunification services for the father. The father was ordered into parenting and anger management classes. The mother, who was described as "non-offending" in both the petition and minute order, was also ordered to attend parenting education. On appeal, the mother contended that there was insufficient evidence to support the order requiring her to attend parenting education classes.

The Court of Appeal concluded that there was no evidence to support the juvenile court's implied conclusion that the mother's attendance in parenting classes was reasonably necessary to avoid a repetition of the father's emotional and physical abuse of the children. Although the juvenile court has wide latitude in making orders necessary for the well-being of the child, such orders are limited to eliminating the conditions that brought the child to the attention of the court. (Welf. & Inst. Code, § 362(a), (c).) The appellate court reasoned that there was no justification for ordering the mother to attend parenting education classes. The mother was the non-offending parent under the petition—she did not abuse her children, fail to protect them, or engage in any other inappropriate behavior. The father's physical abuse was an isolated incident during which the mother immediately interceded, physically restrained him, and directed another to call the police. Moreover, the children were never removed from the mother's home. Therefore, the appellate court reversed the part of the order requiring the mother to attend and complete a parenting education class. In all other respects, the order was affirmed.