What is the burden of proof applied in assessing the reasonableness of reunification services?

Mother contends the juvenile court did not apply any burden of proof in assessing the reasonableness of reunification services because it did not specify the one it used in making its finding. She is correct the court did not articulate the burden of proof it used. However, we must presume on a silent record that the juvenile court used the correct burden of proof. (See Denham v. Superior Court (1970) 2 Cal.3d 557, 564.) The correct burden of proof in assessing the reasonableness of reunification services is clear and convincing evidence. We presume, therefore, the court applied the clear and convincing standard in the absence of any evidence that it used an improper standard. In addition, the record is not entirely silent on the matter. On the preprinted form used for the order after hearing, the order setting the section 366.26 hearing is followed by a finding "[b]y clear and convincing evidence reasonable services have been provided or offered to the child's parents ...."