In re R.R. CA4/2, E076120

Mother (L.F.) is the maternal aunt who had adopted five children; in March 2018 CFS filed dependency petitions after allegations Mother’s husband sexually abused two children. Mother pled no contest and the court sustained the petitions.
Reunification services were later terminated; the three youngest children (H.R., R.R., R.E.) were placed with paternal relatives (Mr. M. and Ms. S.) in October 2019, who were willing to adopt.
CFS recommended termination of parental rights and adoption; reports indicated the children had stabilized in their new home and the prospective adoptive parents had a clear attachment to them.
L.M. (a sibling and former household member) filed a §388 petition asserting a sibling relationship and asking the court to consider the sibling-relationship exception at the §366.26 permanency hearing and to order legal guardianship/unsupervised visitation.
The social worker reported the children expressed they did not want contact with L.M.; at the contested §366.26 hearing the juvenile court found adoption appropriate, denied L.M.’s request under the sibling exception, terminated Mother’s parental rights, and set further permanency review.
L.M. appealed, arguing the court erred in failing to apply the sibling-relationship exception in §366.26(c)(1)(B)(v). The Court of Appeal affirmed.

Issue	Plaintiff's Argument (L.M.)	Defendant's Argument (CFS / Juvenile Court)	Held
Whether termination of parental rights would substantially interfere with the sibling relationship (sufficient evidence)?	L.M.: he lived with the children, served as caregiver/parent, shared significant experiences; severance would be detrimental.	CFS/Juvenile Ct.: children had been separated from L.M. >1 year, very limited visits, and the children expressed they did not want contact; no strong current bond.	Court: Substantial evidence supports implied finding termination would not substantially interfere with the sibling relationship; no reversal.
Whether the juvenile court abused its discretion in weighing any sibling detriment against adoption benefits?	L.M.: even if some detriment existed, the court improperly weighed evidence and should have directly questioned children given possible prior misstatements/manipulation.	CFS/Juvenile Ct.: children’s lives had stabilized, emotional health improved, they wanted adoption; permanency benefits outweigh any sibling detriment.	Court: No abuse of discretion; permanency/adoption benefits outweighed any potential detriment; affirmed.

In re Celine R., 31 Cal.4th 45 (2003) (explains sibling-relationship exception and requirement to weigh detriment against adoption benefits)
In re Elizabeth M., 19 Cal.App.5th 768 (2018) (discusses §366.26 purpose and adoption preference when reunification ended)
In re J.S., 10 Cal.App.5th 1071 (2017) (distinguishes substantial-evidence review for factual bond issues from abuse-of-discretion review for balancing detriment vs adoption)
In re Daniel H., 99 Cal.App.4th 804 (2002) (places burden on party opposing adoption to show substantial interference/detriment)
In re Stephanie M., 7 Cal.4th 295 (1994) (articulates abuse-of-discretion standard and deference to trial court credibility determinations)
In re J.T., 195 Cal.App.4th 707 (2011) (addresses sibling standing to appeal; reflects conflicting authority on standing)