In re G.B.
San Francisco Human Services Agency v. Karen R.
Opinion
Opinion
Humes, J.
Without holding a hearing, the juvenile court denied two requests by appellant Karen R. (mother) to modify an order denying her services to reunify with her son and severely abused infant daughter. Later, and after holding a hearing, the court terminated mother’s parental rights. On appeal, mother challenges these three orders. She argues that the juvenile court erred in not holding an evidentiáry hearing on her modification requests because (1) it initially ordered a hearing on a form order, and (2) a prima facie case was alleged compelling a hearing. She also argues that her parental rights were improperly terminated because her children would benefit from a continuing relationship with her.
We conclude that the failure to hold a hearing on mother’s modification requests does not amount to reversible error. On the first request, the juvenile court did not abuse its discretion in finding that mother failed to allege a prima facie case. On the second request, any possible abuse of discretion was harmless because mother was given an opportunity to be heard, and the court made findings negating the appropriateness of reunification services. We also conclude that mother’s…