In re R.L. CA3, C094112

Background

Four siblings (Jir.Q., Y.L., N.L., and R.L.) were removed in April 2019 after reports and medical findings consistent with excessive corporal punishment and physical abuse; parents were cited for child endangerment.
R.L. (youngest) was placed in a different foster home from her three older siblings because no single home could safely take all four given their special needs; Department continually sought joint placement and ordered sibling visits.
Mother received reunification services, attended some programs and therapy, but engaged inconsistently, made repeated false abuse allegations against caregivers, and therapists concluded she had not meaningfully accepted responsibility.
The juvenile court terminated reunification services, found R.L. adoptable, and at the section 366.26 selection and implementation hearing rejected (1) the beneficial parental relationship exception and (2) the sibling-exception to adoption; it freed R.L. for adoption and placed the other three siblings on a guardianship/monitoring track.
Mother appealed, arguing the court misapplied the beneficial-parental-relationship standard (post-In re Caden C.), erred about the sibling exception, and that the Department violated section 16002 by not placing siblings together. The Court of Appeal affirmed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the beneficial-parental-relationship exception (§ 366.26(c)(1)(B)(i)) applied to R.L.	Dept.: Mother visited and had a positive relationship but the relationship did not outweigh the benefit of adoption; R.L. was young, had spent half her life in foster care, and was strongly attached to her caregiver.	Mother: Juvenile court applied wrong standard and should be remanded under In re Caden C.; her visits and parental role created a relationship whose loss would be detrimental.	Affirmed. Court correctly applied the governing analysis (consistent with Caden C.) and substantial evidence supported findings that, although mother had a parental role, terminating rights was not detrimental in light of R.L.’s age, time in care, and attachment to caregiver.
Whether the sibling-exception (§ 366.26(c)(1)(B)(v)) barred adoption of R.L.	Dept.: Sibling bond did not rise to the level required; R.L. had limited shared experiences with siblings and did not request them outside visits; permanency via adoption outweighed continued sibling contact.	Mother: Severing sibling ties would substantially interfere with the children’s relationships; court should consider impacts on all siblings and preserve their ties.	Affirmed. Court properly focused on detriment to R.L. (not third-party siblings) per Celine R.; evidence failed to show a sibling relationship strong enough to outweigh adoption’s benefits.
Whether Department violated § 16002 by not placing all siblings together	Dept.: Made diligent efforts to locate/assess placements and concluded separate placements were necessary given the children’s special needs and foster-home capacities; court made findings to that effect.	Mother: Dept. failed to comply with statutory presumption favoring sibling placement and should be reversed.	Reversed? No — claim forfeited. Mother did not object below to § 16002 noncompliance; the court had found diligent efforts and appropriate placements and appellate court declined to excuse forfeiture.

Key Cases Cited

In re Caden C., 11 Cal.5th 614 (supreme-court framework for evaluating the beneficial-parental-relationship exception; elements and standards of review)
In re Celine R., 31 Cal.4th 45 (sibling-exception focuses on detriment to the child being adopted, not incidental harm to siblings)
In re L.Y.L., 101 Cal.App.4th 942 (interpretation of sibling-exception’s heavy burden and rarity)
In re Autumn H., 27 Cal.App.4th 567 (early seminal interpretation of the parental-benefit exception)
In re Beatrice M., 29 Cal.App.4th 1411 (discusses beneficial-parental-relationship considerations)
In re Ronell A., 44 Cal.App.4th 1352 (explains adoption as the preferred permanency plan at section 366.26)
In re J.D., 70 Cal.App.5th 833 (remand where juvenile court made scant findings on parental-benefit exception post-Caden C.)
In re D.M., 71 Cal.App.5th 261 (reversed where court failed to analyze the child-focused attachment inquiry required by Caden C.)
In re L.A.-O., 73 Cal.App.5th 197 (discusses parental role vs. beneficial-relationship language in post-Caden C. decisions)
In re S.B., 32 Cal.4th 1287 (forfeiture doctrine in dependency appeals and limited appellate discretion to excuse forfeiture)