Alameda Cnty. Soc. Servs. Agency v. I.T. (In re E.T.), 31 Cal. App. 5th 68

Fraternal twins P.T. and E.T. were removed from Mother (I.T.) in April 2014 and returned in October 2015; they were removed again in April 2017 after Mother relapsed and the Agency filed a supplemental petition.
The juvenile court bypassed reunification services, set a section 366.26 hearing, and ordered supervised visitation beginning at one hour per week; the foster/godparents sought adoption.
Mother entered intensive outpatient treatment (Options), completed parenting and other programs, consistently tested negative for drugs during much of the dependency, and maintained regular supervised and therapeutic visitation and phone contact with the twins.
Testimony showed the children were strongly attached to Mother, derived comfort and anxiety relief from her, but also were thriving and had stability with the godparents who were willing to adopt.
The juvenile court found Mother credible but concluded she failed to show changed circumstances and that her bond with the children was not strong enough to outweigh the benefit of adoption; it denied modification of the order and terminated Mother's parental rights.

Issue	Mother's Argument	Agency's Argument	Held
Whether the "beneficial parent-child relationship" exception to termination (Welf. & Inst. Code § 366.26(c)(1)(B)(i)) applies	Mother maintained regular visitation and a substantial, positive attachment such that terminating rights would harm the children	Children need stability; they are thriving with godparents who will adopt, so adoption preference should control	Court of Appeal: Exception applies — Mother's relationship benefits the children enough to outweigh adoption; termination reversed and remanded for long-term planning
Whether the juvenile court erred in denying Mother's motion to modify the order setting the termination hearing (changed circumstances)	Mother argued changed circumstances and sought reunification or services based on her sustained treatment, sobriety, and parenting improvements	Agency opposed, citing prior unsuccessful reunification and children’s need for stability	Court of Appeal did not decide the modification claim on the merits (procedural mootness after reversal) but noted the claim has substantial prospect of success on remand

In re Anthony B., 239 Cal.App.4th 389 (discusses burden and standards for beneficial-relationship exception at section 366.26)
In re Autumn H., 27 Cal.App.4th 567 (framework for evaluating strength/quality of parent-child bond and variables to consider)
In re Amber M., 103 Cal.App.4th 681 (addresses parent's burden to show beneficial relationship through regular contact and demonstrated benefit)
In re C.B., 190 Cal.App.4th 102 (holds court cannot rely on unenforceable expectation that adoptive parents will permit post-termination contact)