Jayden M., In re (2023) B321967 B321967; filed 7/27/23. ![[Files/CaseFiles/B321967.PDF]] [Opinion PDF](https://www.courts.ca.gov/opinions/archive/B321967.PDF) ## Rule excerpts Welfare and Institutions Code section 361.5(b)(10) and (11). Footnote 9 leaves unresolved cases with no time gap between termination in the sibling’s case and the current dispositional hearing. > We hold that, in assessing whether a parent made a reasonable effort to address a problem from a prior dependency case involving the current child’s sibling or half sibling and where reunification services or parental rights were terminated under subdivisions (b)(10) or (b)(11) of section 361.5, the juvenile court should consider the entire time span between, at the one end, the earliest time a sibling or half sibling was removed from the parent’s custody due to that problem and, at the other end, the dispositional hearing in the current case. — Jayden M., In re (2023) B321967, slip op., p. 14.