The California Court of Appeal has affirmed a custody order that denies a father joint legal custody and unmonitored visitation rights with his daughter, B.B., due to a history of domestic violence. The ruling, filed on November 13, 2026, addresses the complexities of custody arrangements in cases involving allegations of abuse.

This decision affects L.B., the father, who had sought joint custody and unmonitored visitation after a series of incidents that led to his arrest for domestic violence against the child's mother, L.S. The court's ruling emphasizes the importance of child safety in custody decisions, especially in cases involving domestic violence.

Background

The case began when the Los Angeles County Department of Children and Family Services (DCFS) filed a juvenile dependency petition against L.B. in July 2025. The petition alleged that L.B. had physically assaulted L.S. in front of their daughter, B.B., who was born in April 2019. The incident occurred in May 2025 when L.B. attacked L.S. after suspecting her of infidelity. As a result of the assault, both L.S. and B.B. suffered injuries that prompted neighbors to call the police.

After the incident, L.B. was arrested, and a criminal protective order was issued, prohibiting him from contacting L.S. and B.B. The juvenile court subsequently detained B.B. from L.B. and placed her with L.S. under DCFS supervision. Initially, L.B. was allowed monitored visits with B.B., but the court's concerns about his behavior and the ongoing criminal case led to restrictions on his custody rights.

The Ruling

During a six-month review hearing in March 2026, the court considered the recommendations from DCFS, which included granting joint legal custody to L.B. However, the court ultimately decided against this, citing the ongoing criminal protective order that limited communication between L.B. and L.S. The judge stated, "I believe legally I have to order sole legal custody. They can’t talk. Them talking about anything other than court-ordered visitation is a violation of this criminal protective order."

The court awarded sole legal and physical custody to L.S. and denied L.B.'s request for unmonitored visitation. It emphasized the need for L.B. to complete domestic violence classes and individual counseling before any changes to visitation could be considered. The ruling highlighted that joint legal custody would not be appropriate given the restrictions imposed by the protective order.

Impact

This ruling sets a significant precedent regarding custody arrangements in cases involving domestic violence. It underscores that the juvenile court's primary focus must be the best interests of the child, particularly in situations where safety concerns exist. The court's decision illustrates how protective orders can influence custody determinations, ensuring that the victim's safety is prioritized over parental rights.

Going forward, this ruling may impact similar cases where one parent has a history of domestic violence. Courts may be more likely to deny joint custody and unmonitored visitation in such situations, reinforcing the need for protective measures to safeguard children and victims of domestic abuse.

What's Next

L.B. has the option to appeal the ruling, but the court has indicated that any modifications to custody or visitation will depend on the resolution of his criminal case and completion of required counseling programs. No related cases are currently pending.