KATIE

Katie V., R.V.’s mother, seeks extraordinary writ review (Welf. & Inst. Code, § 366.26, subd. (l); Cal. Rules of Court, rule 38.1) challenging the juvenile court’s order terminating reunification services at the 18-month review hearing and setting a section 366.26 permanency planning hearing. Katie contends she was not offered reasonable reunification services and the court erred by applying a preponderance of the evidence standard of proof instead of requiring clear and convincing evidence.

We issued an order to show cause, the San Diego County Health and Human Services Agency (the Agency) responded, and the parties waived oral argument. We conclude that at the 18-month review hearing a preponderance of the evidence standard of proof applies to the reunification services issue, and the court’s order is supported by substantial evidence. Accordingly, we deny the petition.

FACTUAL AND PROCEDURAL BACKGROUND

After R.V. was bom to Katie in June 2003, the Agency filed a dependency petition on her behalf under section 300, subdivision (b), alleging Katie was unable to care for R.V. Katie had no provisions for the baby; she admitted a history of drug use, including crystal…