In Re Albert T‪.‬

The juvenile court denied family reunification services to Peggy L., the mother of Albert T., under Welfare and Institutions Code section 361.5, subdivision (b)(10), which provides that family reunification services need not be offered to a parent of a dependent child if services for a sibling of that child previously had been terminated because the parent failed to reunify with the sibling and the parent thereafter has not made a reasonable effort to treat the problems that led to the siblings removal. On appeal Peggy contends, although the juvenile court previously terminated reunification services for Alberts brother, Alan C., because Peggy failed to reunify with him, the evidence at the disposition hearing for Albert was insufficient to support the courts implied finding she had not subsequently made a reasonable effort to treat the problems that led to Alans removal. We agree and reverse.