In re F.G. CA4/3

INTRODUCTION

P.M. (mother) is the mother of four children who were declared dependents 1 of the juvenile court: F.G. (now 15 years of age), S.G. (13), A.G. (12), and D.G. (4). After reunification services were terminated and the matter was set for a permanency hearing under Welfare and Institutions Code section 366.26 (all further statutory references are to the Welfare and Institutions Code), mother filed a section 388 petition. Mother’s petition asked that D.G. be returned to mother’s care and custody, or that the section 366.26 hearing as to D.G. be continued. The juvenile court found that mother had made a prima facie showing and scheduled an evidentiary hearing on the section 388 petition. After that hearing, the juvenile court denied the petition. On appeal, mother contends that the children’s counsel had a conflict of interest because she could not independently evaluate D.G.’s best interests while continuing to represent F.G., S.G., and A.G., whose statements to the social worker formed a portion of the Orange County Social Services Agency’s (SSA) recommendation against mother’s section 388 petition. We affirm. There was no actual conflict of interest in the children’s…