In re J.C.

J.C.’s mother M.C. (Mother) appeals from the termination of her parental rights. On appeal, she maintains the court erred in denying her Welfare and Institutions Code section 388 modification petition (hereafter 388 petition) and should have applied the “parental benefit exception” to adoption (see § 366.26, subd. (c)(l)(B)(i)). We conclude both contentions lack merit and we affirm the orders.

I

A. Detention

On April 25, 2011, the Orange County Social Services Agency (SSA) placed a hospital hold on J.C. following her birth based on allegations of general neglect. Several months earlier, in February 2011, Mother’s three other children were declared dependent children of the juvenile court pursuant to section 300, subdivision (b). The juvenile court detained J.C. based on evidence Mother had made inadequate progress in her open family reunification case plan with respect to J.C.’s siblings. Mother’s substance abuse was unresolved, she inconsistently drug tested, she received sporadic .prenatal care, and she did not have provisions to care for her newborn.

In its detention report, SSA provided information about several prior child abuse referrals. The first child abuse…