In re G.K. CA2/2

Good Law
Court of Appeal of CaliforniaJanuary 20, 2026B343611California6,696 words

Opinion

Opinion

Chavez, J.

Background The family is comprised of G.K. and mother; the two were originally from Australia and moved to the United States in 2019.

1 All further statutory references are to the Welfare and Institutions Code unless otherwise indicated. 2 The hearing was styled as both a “post permanent plan review” pursuant to section 366.3, as well as a “permanency planning review hearing” pursuant to section 366.26. The January 22, 2025 proceeding functioned as a section 366.26 hearing following the second termination of mother’s reunification services. 3 Section 352 allows the court to continue any hearing beyond the time limit if the hearing is otherwise meant to be held provided the continuance is not contrary to the interest of the minor.

2 G.K. and mother had no contact with presumed father, and he was believed to have died of COVID-19 in Cameroon in 2020.4 Referral and section 300 petition On February 17, 2021, the Los Angeles County Department of Children and Family Services (the Department) received a referral after G.K. was hospitalized on an “involuntary hold . . . for choking mother.” During the hospitalization, G.K. alleged physical and emotional abuse by mother and bore marks…

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