In re S.F. (2023)

One parent's challenge to dependency jurisdiction is normally moot if jurisdiction was established against both parents; Not moot if that parent also challenges disposition orders against them; Standard for removal based on parents' DV; Substance abuse finding lacked substantial evidence - concern that former addict might relapse is not enough without evidence of relapse; Futility exception to forfeiture; "Reason to know" vs "reason to believe" standards for ICWA