In re K.M. CA1/1

CourtCalifornia Court of Appeal
DecidedJanuary 30, 2026
DocketA173984
StatusUnpublished

This text of In re K.M. CA1/1 (In re K.M. CA1/1) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re K.M. CA1/1, (Cal. Ct. App. 2026).

Opinion

Filed 1/30/26 In re K.M. CA1/1 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIRST APPELLATE DISTRICT

DIVISION ONE

In re K.M., a Person Coming Under the Juvenile Court Law.

SAN FRANCISCO HUMAN SERVICES AGENCY, Plaintiff and Respondent, A173984 v. (City & County of San Francisco K.E., Super. Ct. No. JD22-3253) Defendant and Appellant.

K.E. (Mother) appeals from an order terminating her parental rights over her daughter, K.M. She argues that the order must be reversed because the juvenile court erred in declining to apply the beneficial relationship exception under Welfare and Institutions Code section 366.26, subdivision (c)(1)(B)(i).1 She further contends that inquiry under the Indian Child Welfare Act (25 U.S.C. § 1901 et seq.; see § 224 et seq.; ICWA) was inadequate. We conditionally reverse the order and remand for the limited purpose of compliance with ICWA.

1 Undesignated statutory references are to the Welfare and Institutions

Code. I. BACKGROUND A. Detention Through Six-Month Review In September 2022, the San Francisco Human Services Agency (Agency) received a referral from a mandated reporter stating that then one- year-old K.M. had been brought to an emergency room after displaying symptoms of drug ingestion. After a positive toxicology report revealed that K.M. had cocaine in her system, the Agency filed a section 300 petition alleging that K.M. was at risk of serious physical harm because Mother failed to adequately protect her, and that K.M.’s father, who lived separately from Mother, was unable to protect K.M. from Mother’s neglect. The juvenile court declared K.M. a dependent, removed her from her parents’ care, and placed her with a relative. Mother was to receive supervised visitation. In its jurisdiction/dispositional report and an addendum report filed in February 2023, the Agency sought a continuance of the jurisdiction and disposition hearing. The addendum report explained that while Mother was ruled out as the source of the drugs ingested by K.M., she could not explain how K.M. obtained the drugs, and the Agency needed time to inspect Mother’s residence and identify safe adults to care for K.M. In an addendum report filed in March 2023, the Agency recommended the court sustain the allegations in the petition. Mother had agreed to a “safety plan” to ensure K.M. did not have access to drugs and was supervised only by certain individuals. K.M.’s caregiver agreed to facilitate visits with the parents. Another addendum report filed in March 2023 recommended that the case be transferred to Contra Costa County, where Mother currently resided.

2 At the contested jurisdiction/disposition hearing, the juvenile court sustained the amended2 petition, declared K.M. a dependent, and ordered reunification services and supervised visitation for both parents. The court also transferred the case to Contra Costa County. A few months later, in July 2023, the case was transferred back to San Francisco County after the social worker learned that Mother was living with K.M.’s maternal grandfather in San Francisco. In a status review report filed in December 2023, the Agency recommended the termination of reunification services for both parents. The report explained that neither parent had completed any of their court-ordered services, and it was difficult to maintain regular contact with them, as they “have moved from one city to another so much and been so unstable over the year.” A maternal aunt, S.S., expressed interest in adopting K.M. K.M. was placed in the care of S.S. in January 2024. After the six-month review hearing was continued, the Agency filed an addendum report in February 2024, again recommending the termination of reunification services. The social worker reported having a hard time maintaining regular contact with the parents, and minimal progress had been made on their case plan. Additionally, Mother had been “very inconsistent” with visitation.

2 The section 300 petition was amended to reflect that both cocaine and

a medication called Haloperidol were found in K.M.’s system, that Mother had tested negative for those drugs, that the maternal grandparents had a history of drug use or possession, and that Mother was struggling to provide for K.M.’s basic needs.

3 In March 2024, Mother filed a trial brief objecting to the termination of reunification services on the ground that the Agency failed to provide her reasonable services. She also argued that the Agency improperly delegated all authority over visitation to K.M.’s caregiver and did not offer her any visits between September 2023 and November 2023. After the contested review was continued, the Agency filed an addendum report recommending that Mother receive a 30-day extended visit with K.M. Mother had made “significant” progress on her case plan and had been more consistent with visitation in the last two months. The Agency stated it would offer Mother six additional months of reunification services if her 30-day trial went well. At a subsequent hearing, the court granted the Agency discretion to give Mother unsupervised and overnight visitation. The Agency filed an addendum report in May 2024, recommending that reunification services be terminated and a section 366.26 hearing be set. The report explained that, per S.S., Mother had been “very ‘hit or miss’ ” with visitation. The report listed 12 visitation dates that Mother had missed in the last three months. In a subsequent addendum report, the Agency again recommended the termination of reunification services. According to the report, “it has continued to be extremely challenging to meet and communicate with both parents.” S.S. reported that Mother had missed half of her visits with K.M. since mid-March 2024. Mother later told the social worker that S.S.’s information was inaccurate though Mother did not provide further comment. At the review hearing in July 2024, the court terminated Mother’s reunification services and set a section 366.26 hearing for November 2024.

4 B. The Section 366.26 Proceedings In October 2024, the Agency filed a section 366.26 report recommending that adoption be approved as K.M.’s permanent plan and that parental rights be terminated. Mother had missed “almost all of her visits” with K.M. and would only see her “sporadically.” When K.M. was initially detained, the Agency tried to schedule supervised visits “in the community” but Mother did not complete an intake. The Agency then attempted to schedule visits that would be supervised by K.M.’s caregiver, but Mother “did not follow through.” Because visits with Mother had been “very minimal,” K.M. was “not attached” to Mother, and their relationship was “minimal.” The Agency determined that K.M. was likely to be adopted. She had been in S.S.’s care for nine months and had adjusted well to the family. S.S. wished to adopt K.M. The section 366.26 hearing was continued multiple times. The Agency filed an addendum report in April 2025, reiterating that Mother’s visitation with K.M. had been inconsistent. S.S. provided the social worker with a list of the dates on which visits occurred between July 2024 and March 2025. The list showed that Mother visited K.M. one to three times a month, for a total of 15 visits. S.S. said the visits usually happened when she contacts Mother “and not the other way around.” The social worker also reported that she heard K.M. refer to S.S. as “mommy” and that K.M. called Mother by her first name.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

South Bay Transportation Co. v. Gordon Sand Co.
206 Cal. App. 3d 650 (California Court of Appeal, 1988)
In Re Zamer G.
63 Cal. Rptr. 3d 769 (California Court of Appeal, 2007)
In Re Adoption Op Arthur M.
57 Cal. Rptr. 3d 259 (California Court of Appeal, 2007)
Orange County Social Services Agency v. Remberto C.
113 Cal. Rptr. 2d 597 (California Court of Appeal, 2001)
In Re Angel B.
118 Cal. Rptr. 2d 482 (California Court of Appeal, 2002)
In Re Autumn H.
27 Cal. App. 4th 567 (California Court of Appeal, 1994)
In Re John F.
27 Cal. App. 4th 1365 (California Court of Appeal, 1994)
People v. Young
105 P.3d 487 (California Supreme Court, 2005)
El Dorado County Department of Human Services v. I.R.
226 Cal. App. 4th 201 (California Court of Appeal, 2014)
Orange County Social Services Agency v. M.C.
226 Cal. App. 4th 503 (California Court of Appeal, 2014)
Alameda County Social Services Agency v. Aurora P.
241 Cal. App. 4th 1142 (California Court of Appeal, 2015)
Derek W. v. David W.
73 Cal. App. 4th 823 (California Court of Appeal, 1999)
Los Angeles County Department of Children & Family Services v. Margaret M.
138 Cal. App. 4th 529 (California Court of Appeal, 2006)
People v. Ennis
190 Cal. App. 4th 721 (California Court of Appeal, 2010)
San Diego County Health & Human Services Agency v. Sara D.
193 Cal. App. 4th 549 (California Court of Appeal, 2011)
Madera County Department of Social Services v. N.M.
201 Cal. App. 4th 406 (California Court of Appeal, 2011)
Los Angeles County Department of Children & Family Services v. Kristina C.
3 Cal. App. 5th 225 (California Court of Appeal, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
In re K.M. CA1/1, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-km-ca11-calctapp-2026.