In re L.C. CA6

Filed 3/6/26 In re L.C. CA6 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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

SIXTH APPELLATE DISTRICT

In re L.C., a Person Coming Under the H053191, H053360 Juvenile Court Law. (Santa Clara County Super. Ct. No. 24JD027746)

SANTA CLARA COUNTY DEPARTMENT OF FAMILY AND CHILDREN'S SERVICES,

Plaintiff and Respondent,

v.

K.M.,

Defendant and Appellant.

The juvenile court terminated mother K.M.’s parental rights over two-year-old L.C. after denying mother’s petition to reinstate reunification services (Welf. & Inst. Code, § 388). (Welf. & Inst. Code, § 366.26.) Mother argues her recent substantial progress demonstrates it would be in L.C.’s best interest to reinstate reunification services such that the order terminating parental rights must also be reversed. Because the juvenile court did not abuse its discretion in finding mother had not shown that further services would be in L.C.’s best interest, we will affirm both orders. I. BACKGROUND

The Santa Clara County Department of Family and Children’s Services alleged in 2024 that then-infant L.C. was at risk of serious physical harm in his parents’ care due to domestic violence exposure and mother’s erratic and violent behavior. (Welf. & Inst. 1

Code, § 300, subd. (b)(1); undesignated statutory references are to this Code.) According to the petition, mother suffered from bipolar disorder and acted violently toward father in L.C.’s presence. L.C. lived with his father, and father continued to see mother despite having a no-contact restraining order against her. The Department’s interviews with the parents revealed that both mother and father had a history of perpetrating intimate partner violence (IPV). L.C. was detained and placed in the protective custody of the Department in connection with an incident in January 2024 which resulted in mother’s arrest for violating a protective order and father’s arrest on outstanding warrants. The juvenile court sustained the petition, declared L.C. a dependent of the court, removed him from his parents’ custody, and placed him with his paternal grandmother. Both parents were granted reunification services and visitation. The parents were instructed to participate in parent orientation and parenting without violence classes, a substance use assessment, random weekly drug testing, and individual counseling. Mother was instructed to take medications as prescribed and participate in a batterer’s intervention program. Father was instructed to participate in an IPV support group. At the contested six-month review hearing in October 2024, the court terminated reunification services due to each parent’s minimal progress on their case plan. (The juvenile court had continued that hearing to give the parents the opportunity to continue to engage in services.) Mother began the violence intervention program and completed the parenting orientation and class after initial non-engagement. She ultimately did not complete weekly drug testing or individual counseling, attended only a few IPV intervention program sessions, and continued to miss visits before the six-month review hearing. She also resumed her relationship with father. The day before services were terminated, mother began attending counseling. Before the contested selection and implementation hearing, both parents petitioned under section 388 for an additional six months of reunification services. In her February 2025 petition, Mother stated that she had not been taking her bipolar medication before 2