In re V.S. CA1/5

CourtCalifornia Court of Appeal
DecidedJuly 16, 2024
DocketA168829
StatusUnpublished

This text of In re V.S. CA1/5 (In re V.S. CA1/5) 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 V.S. CA1/5, (Cal. Ct. App. 2024).

Opinion

Filed 7/16/24 In re V.S. CA1/5 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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 FIVE

In re V.S., a Person Coming Under the Juvenile Court Law.

MARIN COUNTY HEALTH AND HUMAN SERVICES, Plaintiff and Respondent, A168829 & A169488 v. (Marin County R.S., Super. Ct. No. JV26726A) Defendant and Appellant.

R.S. (Mother) appeals from the juvenile court’s orders placing Mother’s daughter, V.S. (Minor), with the paternal grandparents, and subsequently terminating Mother’s parental rights. We reject the challenges.

1 BACKGROUND1 “Prior Dependency Proceeding “In October 2018, Marin County Health and Human Services (the Department) filed a [Welfare and Institutions Code2] section 300 petition on behalf of [Minor, then two months old]. The petition alleged Mother ‘has a longstanding history of alcohol abuse and has been unable to maintain sobriety for more than a very short period when outside of a residential treatment program.’ The Department stated Mother was ‘charming, smart, capable and a very good mother when she is sober,’ but there had already been multiple incidents of Mother drinking to excess while caring for Minor. Mother had been to treatment about five times in her life. “Mother submitted to jurisdiction and the juvenile court ordered reunification services. Mother received 15 months of reunification services, during which time she relapsed three times. In February 2020, Mother had been sober for six months and Minor was returned to her care. Mother received an additional five months of family maintenance services before dependency was dismissed in July 2020 with custody to Mother. “Current Dependency Proceeding “In October 2022, the Department filed the underlying dependency petition, alleging Mother had relapsed multiple times since the termination of the prior proceeding.

1 Much of the relevant background was set forth in an opinion on a

previous appeal, which we quote at length here. We omit background facts regarding Minor’s father, who is deceased. 2 All undesignated statutory references are to the Welfare and

Institutions Code.

2 “The Department reported Mother first relapsed in the fall of 2020, while living in New York. In December 2020, a New York court granted temporary custody of Minor to the paternal grandmother. Mother entered treatment, and in the fall of 2021, Minor was returned to Mother’s care. In June 2022, Mother relapsed again. In September, Mother left Minor with the maternal grandmother in Marin County and entered a treatment program in Pennsylvania. After the maternal grandmother left Minor with the maternal grandfather, who was in recovery and relapsed while caring for Minor, the juvenile court ordered Minor detained and placed in foster care. “In late November 2022, the juvenile court sustained the petition and ordered reunification services to Mother, including substance abuse and mental health services. That month, Mother began drinking daily while residing in a Marin County sober living home, but initially was able to conceal the relapse. In December, she was discharged from the sober living home after staff searched her room and found empty wine bottles and numerous empty nitrous oxide cannisters. In early January 2023, Mother told the Department she was staying with her boyfriend in New York. While out of state, Mother did not engage in services and did not test, despite multiple testing appointments arranged by the Department. She later told the Department she was drinking heavily throughout this period, and also drove drunk and used cocaine. “In late February 2023, Mother returned to Marin County and entered residential treatment. . . . [¶] In May 2023, shortly before the six-month review hearing, the Department filed a section 388 petition requesting the court terminate reunification services and set a section 366.26 hearing. . . . [¶] . . . [¶] Following the contested hearing [on July 13], . . . [t]he court terminated reunification services and set a section 366.26 hearing.” (R.S. v.

3 Superior Court of Marin County, Oct. 18, 2023, A168434.) This court denied Mother’s writ petition challenging the order. (Ibid.) Shortly thereafter, an evidentiary hearing was held on a section 388 petition filed by the paternal grandparents requesting Minor be placed with them in New York, where they live.3 On July 25, 2023, the juvenile court issued a written order granting the paternal grandparents’ request for placement. Mother appeals from this order (case No. A168829). In advance of the November 2023 section 366.26 hearing, the Department filed a report recommending the juvenile court terminate Mother’s parental rights and set a permanent plan of adoption. On November 7, Mother requested a bonding study, which the juvenile court denied. On November 16, following the contested section 366.26 hearing, the juvenile court terminated Mother’s parental rights and set a permanent plan of adoption. Mother appeals from this order (case No. A169488) and we consolidated the two appeals. DISCUSSION I. Placement With Paternal Grandparents Mother appeals the juvenile court’s order placing Minor with the paternal grandparents. We find Mother lacks standing to appeal this order. To determine whether a parent has standing to appeal a juvenile court’s placement order, a court must “precisely identify [the parent’s] interest in the matter. . . . [A]fter reunification services are terminated or bypassed . . . , ‘the parents’ interest in the care, custody and companionship of the child [is] no longer paramount. Rather, at this point “the focus shifts to the needs of the child for permanency and stability . . . .” ’ [Citation.] For

3 The section 388 petition was filed in April 2023, but the evidentiary

hearing was continued to follow the six-month review hearing.

4 this reason, the decision to terminate or bypass reunification services ordinarily constitutes a sufficient basis for terminating parental rights. (§ 366.26, subd. (c)(1).) A few statutory exceptions to this rule permit the juvenile court not to terminate parental rights when compelling reasons show termination would be detrimental to the child. (Id., subd. (c)(1)(B)(i)-(vi).)” (In re K.C. (2011) 52 Cal.4th 231, 236–237.) Therefore, “[a] parent’s appeal from a judgment terminating parental rights confers standing to appeal an order concerning the dependent child’s placement only if the placement order’s reversal advances the parent’s argument against terminating parental rights.”4 (Id. at p. 238.) For example, a parent may have standing to appeal an order removing a child from a relative placement because “[t]he placement of a dependent child with relatives can, under certain circumstances, make the termination of parental rights unnecessary. (§ 366.26, subd. (c)(1)(A).)” (Id. at p. 237.) Mother argues the placement decision impacted her ability to present evidence supporting the parental-benefit exception to adoption (see post, part III) because her visits with Minor were reduced to twice per month and changed from in-person to virtual. Minor’s placement with the paternal grandparents began in mid-August 2023, only three months before the contested section 366.26 hearing.

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Bluebook (online)
In re V.S. CA1/5, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-vs-ca15-calctapp-2024.