San Diego County Department of Social Services v. Sandra C.

*1130 Opinion

Sandra C. (Mother) appeals from the juvenile court’s findings and orders made at a Welfare and Institutions Code 2 section 366.26 hearing terminating her parental rights as to three of her children. The principal issue raised on appeal is that the termination order must be reversed because the court’s referral to the section 366.26 hearing, achieved at a hearing held in accordance with section 366.22, was void for failure to follow the directions of this appellate court contained in a mandate order.

I

Our previous order 4 was a reaction to a petition for writ of mandate brought by Mother from a section 366.21 order terminating reunification *1131 services and referring the case to a section 366.26 “selection and implementation” hearing. The effect of this trial court order was to terminate reunification efforts after only 12 months of the program. Our unpublished decision, rendered December 9, 1992, found that Mother had made progress in her parenting education, that the social service report had recommended an additional six months of the reunification program, and that “[j]ust when [M]other may have gotten her life together and was ready to participate fully…