C.B. v. Department of Children and Families, 148 So.3d 833 (Fla. 5th DCA 2014)

Father appealed part of the trial court’s dispositional order requiring him to participate in anger management. The Department conceded error in that the evidence presented to the trial court failed to demonstrate a need for such counseling. Florida Rule of Juvenile Procedure 8.410(b)(4) provides that the case plan be “meaningful and designed to address the facts, circumstances and problems on which the court based its order of dependency . . .”

The Fifth District Court of Appeal struck the portion of the disposition order regarding anger management and remanded for an amended order.

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