Riverside County Department of Public Social Services v. Kenneth L.

Lisa P. (Lisa) and Kenneth L. (Kenneth) each appeal from an order terminating their parental rights to Cicely L. (Cicely). Kenneth alone appeals from a subsequent order similarly terminating their parental rights to Cicely’s older brother, David L. (David).

Kenneth contends that reasonable reunification services were not provided to him because he was not allowed any visitation with David and Cicely as long as he was incarcerated in state prison. Kenneth also challenges the juvenile court’s findings that he had not had regular visitation and contact with David and Cicely such that they would benefit from continuing the relationship with him, and that David and Cicely were likely to be adopted, as not supported by substantial evidence. Lisa challenges the same findings on the same grounds, but solely with respect to Cicely. Finally, Lisa contends that the juvenile court erred in refusing to consider evidence of Cicely’s visitation and contact with Lisa’s parents—Cicely’s grandparents— and in excluding such evidence as irrelevant.

We hold that the juvenile court’s orders finding that reasonable reunification services had been provided and terminating reunification…