In re X.A. CA2/1

CourtCalifornia Court of Appeal
DecidedJanuary 31, 2025
DocketB338604
StatusUnpublished

This text of In re X.A. CA2/1 (In re X.A. CA2/1) 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 X.A. CA2/1, (Cal. Ct. App. 2025).

Opinion

Filed 1/31/25 In re X.A. CA2/1 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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

SECOND APPELLATE DISTRICT

DIVISION ONE

In re X.A. et al., B338604

Persons Coming Under the (Los Angeles County Juvenile Court Law. Super. Ct. No. 22CCJP00758)

LOS ANGELES COUNTY DEPARTMENT OF CHILDREN AND FAMILY SERVICES,

Plaintiff and Respondent,

v.

SARAH M.,

Defendant and Appellant.

APPEAL from an order of the Superior Court of Los Angeles County, Mark A. Davis, Judge. Conditionally reversed and remanded with instructions. Aida Aslanian, under appointment by the Court of Appeal, for Defendant and Appellant Sarah M. Dawyn R. Harrison, County Counsel, Kim Nemoy, Assistant County Counsel, and David Michael Miller, Deputy County Counsel, for Plaintiff and Respondent. _______________________

Appellant Sarah M. (Mother) challenges the juvenile court’s order under Welfare and Institutions Code1 section 366.26 terminating her parental rights to minors X.A. (born 2019) and E.A. (born 2021) in favor of a plan involving a maternal relative adopting the children. Mother argues the juvenile court erred in finding the beneficial relationship exception to termination of her parental rights inapplicable. That exception applies when a parent shows all of the following three elements: (1) the parent has consistently visited with the child; (2) “the child has a substantial, positive, emotional attachment to the parent”; and (3) adoption would be detrimental to the child because the benefits the child enjoys from their relationship with the parent outweigh the stability and permanence of adoption. (In re Caden C. (2021) 11 Cal.5th 614, 636 (Caden C.); see § 366.26, subd. (c)(1)(B)(i).) Because Mother had the burden of proof below, her burden on appeal is to show that, as a matter of law, the facts compel the conclusion that she has proven all three elements. Because Mother has failed to make such a showing as to the second element, we must affirm. We need not and do not consider the remaining elements.

1 Subsequent unspecified statutory references are to the Welfare and Institutions Code.

2 We agree, however, with Mother and DCFS that DCFS and the child welfare agency in another county where the case originated failed to adequately inquire whether the children were “Indian children” as defined in the Indian Child Welfare Act of 1978 (ICWA; 25 U.S.C. § 1901 et seq.). On this basis, we conditionally reverse the court’s order terminating Mother’s parental rights as well as those of Luis A. (Father). FACTUAL AND PROCEDURAL BACKGROUND Father did not actively participate in the proceedings below and is not a party to this appeal. We confine our discussion of the factual and procedural background to the portions of it relevant to Mother’s appeal. A. Proceedings in Kern County On October 29, 2021, the Kern County Department of Human Services (KCDHS) filed a section 300 petition on behalf of X.A. and E.A. alleging that on October 27, 2021, Mother was found in a car intoxicated and passed out, slumped over in the passenger seat, with the children in the back seat unsecured. The car was at a stop light, running and in drive, with the driver also passed out. Mother was aware the driver had been drinking and there were open cans of alcohol within reach of X.A. KCDHS also alleged that Mother drank alcohol daily and her substance abuse placed the children at risk. KCDHS asserted claims under subdivision (b) of section 300 that Mother failed or was unable to supervise or protect the children adequately, Father willfully or negligently failed to supervise or protect the children adequately from Mother’s conduct, and Mother and Father were both unable to provide regular care for the children due to their substance abuse.

3 The Kern County juvenile court detained the children on November 1, 2021. On January 10, 2022, the court found the allegations against Mother and Father true and asserted jurisdiction over the children. On February 23, 2022, the court ordered the case transferred to Los Angeles County where Mother resided and where the children had been placed with maternal grandfather (MGF). In a report prepared for the transfer-out hearing, a KCDHS social worker stated that Mother had been regularly visiting the children. B. The Los Angeles County Juvenile Court Accepts the Case and Proceeds to Disposition On March 9, 2022, the Los Angeles County juvenile court accepted the transfer. Mother reported that Father was incarcerated in Kern County. The children remained placed with MGF. In a jurisdiction/disposition report filed on April 13, 2022, DCFS informed the court that Father’s scheduled release date was in July 2022. According to Mother, she and Father separated when the dependency case initiated. Mother was participating in a substance abuse program. She had refused to take an alcohol/drug test on March 8, but had a negative drug test on March 26. At the disposition hearing on April 26, 2022, counsel for DCFS and the minors contended the court should remove the children from Mother due to Mother’s history of alcohol abuse. Mother requested the children be returned to her at MGF’s home, pointing to her consistent compliance with services and programs. Based on the severity of the October 2021 incident, and the relatively short period Mother had been working to

4 achieve sobriety, the court declared the children dependents under section 300, and removed them from Mother and Father, finding by clear and convincing evidence that remaining in either parent’s custody would pose a substantial danger and risk of detriment to the children, and that DCFS had made reasonable efforts to prevent removal. The court ordered DCFS to provide reunification services and visitation for Mother for a minimum of six hours per week. The court ordered Mother to participate in a drug/alcohol program and submit to weekly drug/alcohol testing. C. Family Reunification Period In preparation for the section 366.21, subdivision (e) six- month review hearing, DCFS submitted reports informing the court that the children were placed in a foster home in mid-June. Mother visited the children each week on Wednesday and Saturday for three hours at a time. The monitors stated the visits were going well. Mother would bring snacks, activities, and games, and was attentive and playful with the children. X.A. was excited to visit with Mother and would constantly ask where Mother was, and at times would cry when the visits were ending and not cooperate in getting in the car to leave. When Mother redirected X.A. during visits, X.A. would become upset and hit Mother on her hands and face. E.A. did not become upset when the visits ended. Mother was observed to be patient and caring towards the children. Mother tested positive for alcohol on June 21, 2022, and in July called a social worker to disclose that she had relapsed on three occasions. In August and September, Mother’s alcohol/drug tests were all negative. In last minute information for the court (LMI) reports filed on October 20 and 25, 2022, DCFS notified the court that Mother

5 was hospitalized on October 1 due to a fall. While at the hospital she was placed on an involuntary hold under section 5150, and she was released on October 13. Mother had felt overwhelmed and hopeless, was diagnosed with major depression, and was prescribed Zoloft.

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

Related

In Re Autumn H.
27 Cal. App. 4th 567 (California Court of Appeal, 1994)
San Diego County Health & Human Services Agency v. E.L.
190 Cal. App. 4th 75 (California Court of Appeal, 2010)

Cite This Page — Counsel Stack

Bluebook (online)
In re X.A. CA2/1, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-xa-ca21-calctapp-2025.