I.R., In re (2021) B307093 B307093; filed 2/24/21. ![[Files/CaseFiles/B307093.PDF]] [Opinion PDF](https://www.courts.ca.gov/opinions/archive/B307093.PDF) ## Rule excerpts Removal under Welfare and Institutions Code section 361(c)(1), requiring clear and convincing evidence of substantial danger and no reasonable means of protection without removal. Filed February 24, 2021; publication ordered March 2, 2021. > Rather, the juvenile court must determine whether a child will be in substantial danger if permitted to remain in the parent’s physical custody, considering not only the parent’s past conduct, but also current circumstances, and the parent’s response to the conditions that gave rise to juvenile court intervention. (See In re Alexzander C. (2017) 18 Cal.App.5th 438, 451–452; In re N.M. (2011) 197 Cal.App.4th 159, 170.) — I.R., In re (2021) B307093, slip op., p. 14.