In re A.L.
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In November 2018, the Santa Clara County Department of Family and Children’s Services filed a petition (Welfare and Institutions Code section 3001) relative to three-year-old A.L. A.L. was living with her father; she was placed into protective custody after her father left A.L. with a daycare provider for several days without making arrangements for her care. Father was in custody. The Department could not locate A.L.’s mother. In March 2019, the juvenile court declared A.L. a dependent child, removed her from her father’s care, and ordered family reunification services. Father received services for 16 months. In July 2020, the court terminated those services and scheduled a selection and implementation hearing (section 366.26). Father then filed a section 388 petition. seeking the return of A.L. to his care. In January 2021, after a combined hearing on the 388 petition and selection and implementation, the court found A.L. adoptable and terminated the father’s parental rights.
The court of appeal affirmed, rejecting arguments that the juvenile court abused its discretion in denying the father’s claim of the beneficial parental relationship exception to adoption and did not apply the correct legal standard by basing its determination that the exception did not apply on the finding that father did not occupy a strong parental role in A.L’s life.
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