San Diego County Department of Social Services v. Elizabeth V.

Elizabeth V. appeals the judgment freeing her three-year-old daughter Maria (Maria) from her custody and control. (Civ. Code, § 232.) 1 The court found Elizabeth had abandoned Maria and failed to provide an adequate parental relationship. The court rejected Elizabeth’s alternative plan to place Maria with her maternal grandmother.

The primary focus of this appeal is directed to the court’s decision to limit Elizabeth’s lawyer’s inspection of documents from two files maintained by the county to those documents which the court determined were relevant to the action. Elizabeth says it is only her lawyer who can determine whether the documents are relevant. She asserts the court’s in camera inspection of the files to determine which portions were relevant and, therefore, discoverable by her counsel was prejudicial error. Although we are sensitive to the fundamental interests involved in this type of proceeding, we conclude otherwise and affirm the judgment.

Factual Background

The petition for freedom from custody and control (FFCC) was filed when Maria was three-years-old and after she had been living in a foster home for about two and one-half years.

*1102 Under Civil…