In re S.R.: CACI‑Reportable Findings Preserve Justiciability of Terminated Dependency Appeals

I. Introduction

The California Supreme Court’s decision in In re S.R. (Dec. 1, 2025) addresses a recurring practical problem in juvenile dependency litigation: what happens to a parent’s appeal from a jurisdictional finding after the juvenile court terminates its jurisdiction and reunifies the family? Specifically, the Court resolves a question it left open in In re D.P. (2023) 14 Cal.5th 266: whether a parent’s appeal remains justiciable (i.e., not moot) when the underlying allegation must be reported to the California Child Abuse Central Index (CACI).

The Court holds that a dependency appeal is not moot where the challenged allegation is of a type that the child welfare agency is statutorily required to report for inclusion in CACI and where reversal can lead to removal from CACI or preserve the parent’s right to an administrative grievance hearing. In doing so, the Court significantly clarifies the interaction between:

California’s mootness doctrine in dependency appeals,
the Child Abuse and Neglect Reporting Act (CANRA) in the Penal Code, and
the CACI system and its extensive collateral consequences.

Justice Liu writes for a unanimous Court, reversing the Court of Appeal’s dismissal of the mother’s appeal as moot. Justice Liu also files a separate concurring opinion, joined by Justice Evans, elaborating an important substantive point: lawful self‑defense against a minor cannot constitute “child abuse or neglect” under CANRA and therefore cannot lawfully serve as the basis for a CACI listing.

II. Factual and Procedural Background

The case arises from a volatile family conflict involving S.F. (“Mother”) and her three daughters, then aged 22, 16, and 12. The incident giving rise to jurisdiction occurred after escalating disputes over the adult daughter’s boyfriend living in Mother’s home:

Mother directed the eldest daughter (22) to move out. The 16‑year‑old left with her.
The two older daughters then took the youngest child (12, with special needs) from Mother’s home without permission, later returning her after Mother threatened to call police.
The next morning, the two older daughters confronted Mother at home. Witnesses described the daughters as attempting to take over the house and appearing ready to fight Mother.

During the confrontation:

Mother and the middle daughter (16) screamed at each other.
Mother, perceiving an imminent physical threat, hit the middle daughter twice and struck or pushed her with the pole end of a shovel.
Believing the eldest daughter was reaching for a weapon in her purse, Mother brandished a camping knife, shouted that it was her house, and made threats, including statements that someone was “about to get killed.”
Mother called the police and the county child abuse hotline, claiming self‑defense.

Initially, the middle daughter told responders that Mother had injured her torso with the shovel and had repeatedly threatened her, including in the context of the daughter’s sexual orientation. Based on this incident, the Los Angeles County Department of Children and Family Services (“the Department”) removed the 16‑ and 12‑year‑old from Mother’s care.

However, after detention:

Both younger daughters reported that the eldest had employed a “sister code” to coach their initial statements.
The middle daughter said the visible torso mark was not caused by the shovel but by her own rubbing at her sister’s direction.
She also stated that Mother unintentionally hit her while intervening between Mother and the eldest daughter.

At the combined jurisdictional and dispositional hearing, all parties agreed Mother was defending herself; the dispute centered on whether her response was reasonable in degree and duration. The juvenile court found:

Mother’s reaction “was not reasonable and longer than the perceived threat lasted,” and that grabbing a shovel and hitting the middle daughter, leaving a mark, and then grabbing a knife and threatening to kill the daughters “was [not] justified” and “escalated the situation.”

On that basis, the court:

Sustained the dependency petition under Welfare and Institutions Code section 300; and
Removed the two younger daughters from Mother’s custody, ordered counseling, and limited Mother to monitored visitation.

Mother appealed. While the appeal was pending:

At the six‑month review, the court returned the children to Mother.
At the 12‑month review, the court terminated dependency jurisdiction entirely.

With jurisdiction terminated and the family reunified, the Court of Appeal notified the parties it was considering dismissing Mother’s appeal as moot. Mother argued the appeal remained live because the sustained allegation was reportable to CACI and would have lasting consequences. The Court of Appeal nonetheless dismissed, reasoning there was no evidence of actual reporting and describing the incident as a one‑time event with no additional stigmatizing findings.

The Supreme Court granted review to decide whether a demonstrated duty to report to CACI suffices to defeat mootness in a terminated dependency case.

III. Summary of the Supreme Court’s Holding

The Supreme Court reverses the Court of Appeal and holds:

Ongoing harm. Mother has demonstrated ongoing harm because the sustained allegation is one that the Department is statutorily required to report to the Department of Justice (DOJ) for inclusion in CACI under Penal Code section 11169, subdivision (a). Courts may presume, under Evidence Code section 664, that the Department will perform this duty.
Redressability. Reversal of the jurisdictional finding can effectively redress that harm in two ways:
- It may prompt the Department to withdraw or reclassify the report as “not substantiated,” requiring DOJ to remove Mother from CACI (§ 11169, subd. (a), (h)); and/or
- It preserves Mother’s right to a grievance hearing to challenge any continued CACI listing, a right that would otherwise be barred once “a court of competent jurisdiction” has determined abuse occurred (§ 11169, subd. (e)).
Result. Because Mother has shown “a specific legal or practical consequence that would be avoided upon reversal of the jurisdictional findings” (In re D.P., supra, 14 Cal.5th at p. 273), her appeal is not moot. The Court remands to the Court of Appeal to decide Mother’s substantive challenges, including her claim of lawful self‑defense.

In his concurring opinion, Justice Liu (joined by Justice Evans) further concludes that:

Under existing self‑defense statutes and CANRA’s definitions, conduct that constitutes lawful self‑defense against a minor cannot legally be “child abuse or neglect” for CANRA purposes.
Accordingly, such conduct cannot provide a lawful basis for CACI inclusion; agencies must refrain from reporting it and must seek removal where self‑defense is later established.

IV. Detailed Analysis

A. Precedents and Statutory Framework

1. In re D.P. and the modern mootness framework in dependency appeals

In re D.P. addressed whether a parent’s appeal from a dependency jurisdictional finding is moot after the juvenile court has terminated jurisdiction and there are no longer active orders affecting custody or visitation. The Court established key principles:

Courts decide only “actual controversies” and do not issue advisory opinions.
A case becomes moot when it is impossible to grant “effective relief.”
“Effective relief” requires (1) an ongoing harm and (2) a harm that is redressable by the requested ruling.
“Stigma alone” is insufficient; the stigma must be tied to concrete legal or practical consequences.
Even if a case is technically moot, appellate courts retain discretion to decide the merits in appropriate circumstances.

In D.P., the father argued his jurisdictional finding could lead to CACI listing. The Court rejected this as too speculative because:

The allegation was one of general neglect, and father did not show that general neglect of the sort found in his case was reportable to CACI; and
The Department affirmatively represented that it had not reported the finding, and that it was ineligible for CACI inclusion.

Thus, there were “two layers of uncertainty” about CACI consequences, and no showing of a concrete, redressable harm. In re S.R. now addresses the scenario that D.P. left unresolved: when the allegation is plainly of a type that must be reported to CACI.

2. CANRA and CACI: the reporting and grievance scheme

The Child Abuse and Neglect Reporting Act (CANRA) (Pen. Code, §§ 11164–11174.3) creates a comprehensive framework for:

What constitutes reportable “child abuse or neglect,”
Who must report it,
How agencies must investigate reports and classify them, and
When and how substantiated reports must be transmitted to DOJ for inclusion in CACI.

Key statutory features include:

Definitions. CANRA distinguishes:
- Neglect (general and severe) (§ 11165.2); and
- “Child abuse or neglect” in § 11165.6, which covers:
  - Nonaccidental physical injury or death inflicted on a child,
  - Sexual abuse (§ 11165.1),
  - Neglect (§ 11165.2),
  - Willful harming or injuring or endangering a child (§ 11165.3), and
  - Unlawful corporal punishment or injury (§ 11165.4).
Substantiated reports. A report is “substantiated” when an investigator, after an “active investigation,” determines that it is more likely than not that child abuse or neglect occurred. (§ 11165.12, subd. (b); § 11169, subd. (a).) Reports found to be false, inherently improbable, accidental, or outside CANRA’s definitions must not be classified as substantiated.
Mandatory reporting to CACI. For “substantiated reports of child abuse or severe neglect,” the reporting agency “shall forward” the report to DOJ for inclusion in CACI. (§ 11169, subd. (a).)
Notice and grievance rights. When an agency forwards such a report, it must notify the individual, who then has a right to an internal grievance hearing before the agency. (§ 11169, subd. (c)–(d).) The grievance procedure “shall satisfy due process requirements.” (§ 11169, subd. (d).)
Denial of grievance based on court findings. If “a court of competent jurisdiction has determined that suspected child abuse or neglect has occurred,” the agency must deny the grievance hearing request. (§ 11169, subd. (e).)
Correction and removal. If a report is later determined “not substantiated,” whether via grievance hearing or court proceeding, the agency must notify DOJ, which must then remove the person from CACI. (§ 11169, subds. (a), (h).)
Judicial review. An adverse grievance decision is reviewable via a petition for administrative mandamus under Code of Civil Procedure section 1094.5, and the superior court’s order denying mandamus is appealable. (In re C.F. (2011) 198 Cal.App.4th 454, 458–459.)

CACI listings have far‑reaching consequences. As the Court reiterates, CACI checks are:

Required for foster and adoptive placements, licensing, and many childcare employments (Health & Saf. Code, §§ 1522.1, 1596.877);
Available to an array of agencies, employers, and law enforcement entities under Penal Code section 11170; and
Potentially stigmatizing and disqualifying, even when not legally dispositive of hiring or licensing decisions.

Amicus ACLU data, cited in D.P. and referenced again in S.R., show that approximately 30 percent of CACI reports are removed after grievance hearings—underscoring the material value of that process to affected individuals.

B. The Court’s Legal Reasoning on Mootness in In re S.R.

1. Ongoing harm: presuming CACI reporting for reportable allegations

The first mootness prong—ongoing harm—is satisfied if Mother faces a continuing legal or practical detriment from the challenged finding. Here, that detriment is her inclusion (or imminent inclusion) in CACI.

The Court reasons:

The sustained allegation concerns Mother’s “physical violence” against her daughter, a type of conduct that clearly falls within CANRA’s definition of reportable child abuse or severe neglect.
Section 11169, subdivision (a), states that such substantiated reports “shall” be forwarded to DOJ for CACI inclusion.
The Department concedes it is required to report this allegation and acknowledges that it is appropriate for courts to presume this duty will be performed.

Under Evidence Code section 664, courts presume “official duty has been regularly performed.” Thus, absent evidence to the contrary, courts may and should assume that a child welfare agency will carry out its CANRA duty to report substantiated abuse to CACI. There is no statutory time limit on this reporting obligation; the report may be transmitted even after dependency and appellate proceedings end. As the Court puts it, it is “not speculative” to conclude Mother is or will be listed in CACI, and that such a listing has serious lifelong implications.

This contrasts sharply with D.P.:

There, the allegation was of “general neglect,” and the father did not show that such allegations were reportable to CACI.
The Department affirmatively represented that the allegation was not reportable and had not been reported.
Accordingly, the Court in D.P. found “two layers of uncertainty” (about reportability and actual reporting) and deemed the CACI‑based harm too speculative.

In S.R., by contrast, there is no dispute that the allegation is in the reportable category, and no representation that it has not and will not be reported. The Court therefore accepts CACI listing as a concrete, ongoing harm.

The Court also acknowledges a practical concern raised by amici and the Department: counsel’s inquiry into a client’s CACI status could, in a close case, trigger reporting that might not otherwise have occurred, creating an “ethical quandary.” Recognizing this tension, the Court emphasizes that:

Its holding addresses the clear case where reportability is undisputed; and
In less certain cases, appellate courts retain discretion to review technically moot appeals where fairness or guidance considerations justify doing so.

2. Redressability: removal from CACI or preservation of the grievance process

The second mootness prong—redressability—requires that a favorable appellate decision be capable of remedying or mitigating the ongoing harm. The Court identifies two independent ways in which reversal of the jurisdictional finding can provide “effective relief”:

Potential removal from CACI.
Under section 11169, subdivision (a), if a previously filed report “proves to be not substantiated,” DOJ must be notified and “shall not retain the report.” Moreover, section 11169, subdivision (h), provides that if, after a grievance hearing or court proceeding, it is determined that the CACI listing was based on a report that was “not substantiated,” DOJ must remove the listing.

Thus, if the Court of Appeal reverses the jurisdictional finding (for example, for insufficiency of the evidence or because the conduct was lawful self‑defense), the agency may:
- Reclassify the report as “not substantiated,” and
- Notify DOJ, resulting in removal of Mother’s name from CACI.
That possibility alone suffices for redressability; the appellate court need not be certain that removal will occur, only that it is a realistic, legally available consequence of reversal.
Preserving the right to a grievance hearing.
Section 11169, subdivision (e), provides that if “a court of competent jurisdiction has determined that suspected child abuse or neglect has occurred,” any request for a CACI grievance hearing “shall be denied.” A sustained jurisdictional finding in dependency court is such a determination.

If that finding is reversed on appeal, the statutory bar disappears. Mother regains the full grievance hearing described in section 11169, subdivision (d), with:
- Due process protections, and
- Subsequent judicial review via administrative mandamus (Code Civ. Proc., § 1094.5).
As D.P. noted, grievance hearings are meaningful: roughly 30 percent of CACI reports are removed after such proceedings. Preserving access to that process therefore has substantial practical value.

Crucially, the Court rejects the Department’s argument that because Mother does not deny the underlying physical acts, reversal would not ultimately help her. For mootness, the question is not whether Mother will win in the CACI process, but whether reversal gives her a legally cognizable avenue for relief. By restoring the chance of removal from CACI or success at a grievance hearing, reversal satisfies redressability.

3. Rejecting the Department’s substantive argument at the mootness stage

The Department argued that Mother’s appeal was moot because, in its view, even if Mother acted in reasonable self‑defense, her conduct still counted as reportable child abuse under CANRA and thus must be reported to CACI. On that view, reversal recognizing self‑defense would not change her legal status.

The Court declines to decide this substantive CANRA issue in the context of mootness:

The dispute about the legal effect of self‑defense is properly a merits question (to be addressed, if at all, in later proceedings) rather than a predicate to appellate jurisdiction.
For mootness, it is enough that reversal would restore Mother’s eligibility for a grievance hearing and create the legal possibility of CACI removal; the Court need not predict how agencies or courts will ultimately resolve those issues.

This deferential approach preserves the jurisdictional inquiry as distinct from the ultimate merits of Mother’s defenses, including self‑defense—a separation that is underscored by Justice Liu’s separate concurrence, discussed next.

C. Concurring Opinion: Self‑Defense and CANRA’s Definition of “Child Abuse or Neglect”

Justice Liu’s concurrence addresses the Department’s underlying substantive premise: that even lawful self‑defense against a minor is still “child abuse” for CANRA and CACI purposes. He finds this view untenable.

1. Statutory self‑defense in California

California law expressly codifies the right to self‑defense:

Penal Code section 692 permits “lawful resistance to the commission of a public offense” by the person about to be injured or by others.
Section 693 authorizes “resistance sufficient to prevent the offense” to prevent an offense against oneself, one’s family, or a family member.
Civil Code section 50 allows “any necessary force” to protect oneself or one’s property from wrongful injury.

Case law clarifies that:

A person may resist a continuing assault with reasonable force appropriate to the circumstances (People v. Myers (1998) 61 Cal.App.4th 328, 335).
Reasonableness is judged by how the situation reasonably appeared to the defendant at the time (People v. Minifie (1996) 13 Cal.4th 1055, 1068).

These provisions and cases establish self‑defense as not merely a mitigation factor but a complete justification: conduct that constitutes lawful self‑defense is not wrongful.

2. CANRA’s “child abuse or neglect” definition and legislative context

CANRA’s key definition provision, section 11165.6, broadly includes physical injury inflicted on a child “by other than accidental means,” along with sexual abuse, neglect, willful harm, and unlawful corporal punishment. It also includes two explicit exclusions:

Mutual affray between minors; and
Injury caused by reasonable, necessary force used by a peace officer acting within scope of employment.

The Department argued that, because the statute does not explicitly mention self‑defense by parents or others, such conduct falls within the “nonaccidental injury” category and must be reported.

Justice Liu rejects this reading by invoking the principle that the Legislature is presumed to be aware of existing law when it legislates (In re Greg F. (2012) 55 Cal.4th 393, 407). At the time CANRA was enacted and later amended, California’s self‑defense statutes were long‑established. The Legislature could have stated that “child abuse or neglect” includes self‑defensive conduct “notwithstanding” those statutes; it did not. In the absence of such express displacement, background justifications like self‑defense remain fully operative.

He further notes that the specific references to mutual affray and police use of force do not imply that all other justified uses of force are excluded from the definition of “lawful” conduct. Rather, they address particular recurring contexts and do not repeal or limit the general self‑defense statutes.

3. Support from People v. Clark and Gonzalez

Two Court of Appeal decisions buttress the concurrence’s conclusion:

People v. Clark (2011) 201 Cal.App.4th 235.
There, the court held that a jury should have been instructed on self‑defense as a defense to criminal child abuse under Penal Code section 273a. The court found no indication that self‑defense was inapplicable when the aggressor is a minor, and refused to “read into the statute a limitation that is not there.” It emphasized that the Legislature should not be presumed to have intended to criminalize the exercise of a right (self‑defense) it has affirmatively granted.
Gonzalez v. Santa Clara County Dept. of Social Services (2014) 223 Cal.App.4th 72.
Gonzalez held that the longstanding “parental privilege” to use reasonable physical discipline must be incorporated into CANRA. Because some CANRA definitions of child abuse are almost verbatim criminal counterparts, the court reasoned that CANRA could not be interpreted to treat reasonable disciplinary acts as reportable “child abuse” when they are not criminally abusive. Thus, parents accused of CANRA child abuse may invoke the same privilege that negates or limits criminal culpability.

Justice Liu analogizes: just as Gonzalez read the parental discipline privilege into CANRA’s definition of reportable abuse, so too must CANRA be read in harmony with self‑defense statutes. If an act is justified as self‑defense in the criminal context, it is not “child abuse or neglect” for CANRA and CACI purposes.

4. Practical directives for agencies

Although concurring and not formally part of the majority holding, Justice Liu’s opinion provides clear guidance:

Agencies may not report conduct to CACI if it constitutes lawful self‑defense against a minor.
If new information or later adjudication shows that a previously reported incident was lawful self‑defense, the agency must notify DOJ so the entry can be removed.
Agencies should “refrain from advancing” the position that lawful self‑defense is still CANRA “child abuse” whenever the individual demonstrates that self‑defense underlies the conduct in question.

In combination with the majority opinion, this concurrence strengthens the substantive protections around CACI listing, at least where self‑defense or reasonable parental discipline is at issue.

D. Relationship Between CANRA/CACI and Dependency Jurisdiction

Mother and amici argued that CANRA’s definitions of “child abuse or severe neglect” are narrower than the grounds for juvenile dependency jurisdiction under Welfare and Institutions Code section 300. The Court agrees in general terms:

CACI is limited to substantiated “child abuse or severe neglect” (Pen. Code, § 11169, subd. (a); § 11165.6),
Whereas dependency jurisdiction under section 300 can rest on a broader set of parental failings or risks not all of which rise to CANRA’s threshold of “abuse” or “severe neglect.”

The Court stops short of fully mapping the overlap, acknowledging that the precise scope of CANRA vs. section 300 is “beyond the scope” of this decision. But its recognition that CANRA is narrower has several implications:

Not every jurisdictional finding will be CACI‑reportable;
Parents and counsel should carefully analyze whether a particular sustained allegation falls within CANRA’s definitions; and
CACI concerns will be particularly salient in cases involving physical injury, sexual abuse, or severe neglect—less so in purely prospective‑risk jurisdictional findings or milder neglect scenarios.

E. Discretionary Review in Technically Moot Dependency Appeals

While holding that S.R. is not moot, the Court reiterates a key principle from D.P.: even when a dependency appeal is moot, appellate courts possess inherent discretion to decide the merits. The Court references multiple reasons why courts might exercise this discretion:

To resolve recurring legal issues that otherwise evade review due to the short duration of dependency proceedings;
To correct particularly egregious or clearly erroneous findings that carry enduring stigma or potential collateral consequences; or
To provide guidance to trial courts and agencies on important statutory or constitutional questions.

In the CACI context, this discretionary authority offers a safety valve when parents cannot clearly prove reportability without risking triggering CACI reporting through their own inquiries. Even if an appeal is determined to be technically moot (for example, because the allegation is likely but not indisputably reportable), appellate courts may still choose to reach the merits to protect parents from enduring, unreviewed stigma and to clarify legal standards for agencies.

V. Complex Concepts Explained

1. Mootness and “effective relief”

A case is “moot” when events have so changed the situation that a court’s decision can no longer have any real‑world impact on the parties. California courts ask:

Is there an ongoing harm to the appellant?
Can the court’s decision provide “effective relief” from that harm?

If both answers are “yes,” the case is not moot. Importantly, “effective relief” does not mean guaranteed success; it means a realistic opportunity for meaningful legal benefit. In S.R., that benefit is the possibility of CACI removal or a fair chance to contest listing through a grievance hearing.

2. CACI and substantiated reports

The Child Abuse Central Index (CACI) is a statewide database maintained by DOJ. It contains names and limited information about individuals against whom there are substantiated reports of child abuse or severe neglect. Only certain types of allegations (physical abuse, severe neglect, sexual abuse, etc.) and only those found “substantiated” after investigation may be reported.

Once listed, individuals typically remain in CACI until age 100 unless:

The report is reclassified as “not substantiated,” or
A grievance hearing or court proceeding results in a finding that the listing was improper, triggering mandatory removal.

3. Grievance hearings and administrative mandamus

A CACI grievance hearing is an internal administrative process conducted by the reporting agency (e.g., a county child welfare department). It allows the listed person to:

Challenge the evidence underlying the substantiated finding,
Present their own evidence and witnesses, and
Argue that the conduct does not meet CANRA’s definitions of child abuse or neglect.

If the individual loses, they can file a petition for administrative mandamus under Code of Civil Procedure section 1094.5 in superior court, asking a judge to independently review the agency’s decision. The superior court’s ruling can then be appealed.

4. Self‑defense in the child‑abuse context

Self‑defense is a legal doctrine allowing a person to use reasonable force to prevent or stop an imminent or ongoing unlawful attack. The force must:

Be directed at preventing or stopping the attack,
Be proportionate to the threat, and
Be based on a reasonable perception of danger.

In criminal law, if an act qualifies as lawful self‑defense, it is not a crime. In the CANRA/CACI context, as Justice Liu’s concurrence explains, the same principle should apply: if an adult reasonably defends against a minor’s attack, the resulting injury is not “child abuse or neglect” for reporting purposes, even though the child is the one injured.

5. Dependency jurisdiction under Welfare and Institutions Code section 300

Section 300 authorizes juvenile courts to take jurisdiction over children when they are at risk of harm due to parental conduct (abuse, neglect, substance abuse, domestic violence, etc.). The standard for jurisdiction is comparatively broad and prospective: the court asks whether the child has suffered or is at substantial risk of suffering harm.

Because jurisdiction is preventive and protective, courts may assert jurisdiction even when parental conduct would not satisfy CANRA’s narrower definitions of “child abuse or severe neglect.” That is why not every dependency finding leads to CACI inclusion—and why the Supreme Court in S.R. emphasizes the narrower reach of CANRA.

VI. Likely Impact and Future Litigation

A. Implications for parents and their counsel

For parents, In re S.R. has immediate practical significance:

A dependency appeal is not automatically mooted by successful reunification and termination of jurisdiction if the sustained allegation is CACI‑reportable.
Parents now have a clear framework: demonstrate that the challenged finding is of a type that “shall” be reported to CACI, and the appeal survives a mootness challenge.
Even if CACI reporting has not yet occurred, the presumption of regular performance of official duty allows courts to treat CACI consequences as real and ongoing.

Counsel in dependency cases should:

Identify early whether alleged conduct falls within CANRA’s “child abuse or severe neglect” categories;
Ensure the record allows appellate courts to see that a CACI reporting duty exists (e.g., by clarifying the precise grounds sustained);
Be cautious about triggering reporting by direct inquiries, especially in borderline cases; and
On appeal, expressly frame CACI consequences as the concrete harm that defeats mootness.

B. Guidance for juvenile courts and appellate courts

Juvenile courts will need to:

Recognize that jurisdictional findings may have significant collateral consequences beyond the life of the dependency case;
Be precise in their findings, including whether conduct meets CANRA’s definitions of “abuse” or “severe neglect” versus lesser forms of neglect or risk; and
Understand that sustained findings in reportable categories may keep related appeals alive even after jurisdiction is terminated.

Courts of Appeal, in turn, must:

Apply S.R. and D.P. to analyze mootness based on CACI consequences;
Presume reportable allegations will be reported unless the record affirmatively shows otherwise; and
Exercise their discretionary authority to hear technically moot cases when fairness or systemic guidance warrants review—particularly in light of the ethical quandary around CACI inquiries.

C. Effects on child welfare agencies and DOJ

For agencies like the Department and DOJ, S.R. and the concurrence collectively imply that:

They must carefully assess whether a substantiated finding truly meets CANRA’s “child abuse or severe neglect” standard before reporting to CACI.
If there is credible evidence of lawful self‑defense or reasonable parental discipline, they must factor those justifications into their classification decisions.
Once a court reverses a dependency finding or upholds a self‑defense claim, agencies should proactively revisit any corresponding CACI listings and initiate removal where warranted.

Agencies may also see:

An increase in CACI grievance hearings, now that parents will more often preserve their right to such hearings through successful appeals; and
More petitions for administrative mandamus challenging adverse grievance decisions.

D. Open questions and future litigation

In re S.R. clarifies much but leaves several questions for future cases:

Borderline reportability. What happens when the allegation is plausibly but not clearly CACI‑reportable, and the agency is silent on whether it has or will report? S.R. hints that such cases might be declared moot, with the Court of Appeal then deciding whether to exercise discretionary review.
Scope of self‑defense and discipline privileges. How far do the self‑defense and parental discipline protections extend in the context of CANRA and CACI, especially where force is substantial but arguably reasonable in context? Justice Liu’s concurrence provides a framework but does not address every borderline scenario.
Interaction with federal due process. The Court again cites Humphries v. County of L.A. (9th Cir. 2009) 554 F.3d 1170 regarding CACI’s impact. How California’s clarified mootness and self‑defense doctrines will interact with future federal due process challenges to CACI practices remains to be seen.
Weight of the concurrence. Although only two justices joined Justice Liu’s self‑defense concurrence, its detailed statutory and precedential analysis may be highly persuasive to lower courts and agencies, likely shaping practice absent contrary authority.

VII. Conclusion

In re S.R. is a significant development at the intersection of juvenile dependency law, CANRA, and the CACI system. The Court establishes a clear rule: when a parent shows that a sustained jurisdictional allegation must be reported to CACI, and that reversal could lead to removal from the index or preserve access to a grievance hearing, the appeal is not moot despite termination of dependency jurisdiction. This closes a doctrinal gap left open by In re D.P. and ensures that serious, long‑term collateral consequences do not evade appellate review simply because the underlying dependency case has formally ended.

The separate concurrence adds an important substantive safeguard: conduct that constitutes lawful self‑defense against a minor, like reasonable parental discipline, is not “child abuse or neglect” within CANRA’s meaning and cannot lawfully form the basis for CACI inclusion. Together, the majority and concurrence reinforce both the procedural rights of parents to appellate and administrative review and the substantive limits on what conduct may justifiably trigger the lasting stigma and practical burdens of a CACI listing.

In the broader legal context, In re S.R. confirms that:

Dependency findings can have enduring consequences beyond child custody and visitation;
Those consequences can preserve justiciability long after the dependency case is closed; and
California courts will scrutinize both the procedural and substantive bases for CACI listings to ensure they comport with statutory schemes and fundamental fairness.

For practitioners, agencies, and families alike, In re S.R. marks a critical clarification of rights and obligations in a legal terrain where the stakes—for parental reputations, employment prospects, and future caregiving opportunities—are exceptionally high.

In re S.R.: CACI-Reportable Findings Preserve Justiciability of Terminated Dependency Appeals