M.V., In re (2022) D079473 D079473; filed 4/22/22. ![[Files/CaseFiles/D079473.PDF]] [Opinion PDF](https://www.courts.ca.gov/opinions/archive/D079473.PDF) ## Rule excerpts Welfare and Institutions Code section 361(c)(1): alternatives to removal; quoting In re Jasmine G. (2000) 82 Cal.App.4th 282, 284. Filed April 22, 2022; publication ordered May 17, 2022. > Section 361, subdivision (c)(1), requires a second condition be met before the juvenile court may remove a child from her parent’s custody. There must also be clear and convincing evidence of “no reasonable means” of protecting the child other than removal. (§ 361, subd. (c)(1).) In other words, “California law requires that there be no lesser alternative before a child may be removed from the home of his or her parent.” (Jasmine G., supra, 82 Cal.App.4th at p. 284, italics added.) As a lesser alternative, section 361 expressly requires the juvenile court to “consider, as a reasonable means to protect the [child],” “[t]he option of removing an offending parent . . . from the home.” (§ 361, subd. (c)(1)(A), italics added.) — M.V., In re (2022) D079473, slip op., p. 26.