Santa Clara County Department of Family & Children's Services v. Eileen Y.

Introduction

Alvia Y. is the father and Eileen Y. the mother of dependent children Joanna Y. and Tiffany Y. In appeal No. H007667, father and mother separately challenge the termination of their parental rights as to Joanna (Civ. Code, § 232) and the termination of reunification services and *437 visitation as to Tiffany (Welf. & Inst. Code, § 366.22). 1 They argue the court committed reversible error: (1) by finding that reasonable reunification services had been offered to them; (2) by finding that father had been convicted of molesting and murdering a third daughter and had abandoned Joanna; (3) by choosing adoption as Joanna’s long-term plan; and (4) by not recusing the district attorney from representing Joanna when that office was prosecuting father.

During the pendency of appeal No. H007667, Tiffany’s section 366.26 hearing was held. The court freed Tiffany for adoption and terminated father’s and mother’s parental rights to her. Each parent timely appealed from the judgment (No. H008183), and we ordered that that appeal be considered with appeal No. H007667. 2 In the latter appeal, mother and/or father contend (1) the evidence at the section 366.26 hearing was…