CA4/3

INTRODUCTION

Sandra J. and Abel V., Sr., the parents of three boys, Andrew, Abel., Jr., and Abraham V., appeal from orders of the juvenile court. Sandra appeals from an order 1 denying her motion under Welfare & Institutions Code section 388 and an order terminating her parental rights under section 366.26. Abel, Sr., appeals from an order terminating his parental rights. We affirm the orders. Sandra did not meet her burden to show changed circumstances. She also did not meet her burden with respect to the beneficial relationship exception to the termination of her parental rights. Abel, Sr., maintains that the juvenile court erred when it found the children adoptable, a prerequisite to termination of parental rights. The court had substantial evidence on which to base a finding of adoptability. The termination of Abel, Sr.’s parental rights on this ground was therefore within the court’s discretion.

FACTS

Orange County Social Services Agency (SSA) detained Abel, Jr., at birth in February 2010, after a toxicology screen revealed the presence of amphetamines in his system. Sandra admitted to smoking crystal methamphetamine five days before Abel, Jr.’s birth and using drugs…