In Re Christina L.

Julie B. (Mother) appeals the judgment of the juvenile court terminating her parental rights concerning her daughter, Christina L., pursuant to Civil Code section 232 Mother contends the juvenile court erred in overruling her demurrer and motion to dismiss the petition, in which she argued she received inadequate notice of the allegations on which the petition was based, due to form pleading of the statutory language in the petition. Mother also argues the focus of the proceedings was improperly shifted from the original grounds upon which dependency was established, an unsanitary home environment, to new allegations of a lack of a parental relationship with Christina. ( In re Venita L. (1987) 191 Cal.App.3d 1229 [ 236 Cal.Rptr. 859 ].) Mother further argues the record contains insufficient evidence to support two findings made by the trial court in connection with the judgment: reasonable reunification services were offered to Mother, and Mother would fail to develop an adequate parental relationship with Christina in the future.

After first finding no notice defect and no deprivation of due process in the manner in which this petition was pled and pursued, when the factual and…