Orange County Social Services Agency v. Jill V.

*224 Opinion

Cody W., bom with heroin in his system, was removed from Jill V.’s custody in December 1991, when he was four months old. Jill, a long-time abuser of drugs, was incarcerated in various facilities across the state for much of the next two years. She was in custody, but present in court, when her parental rights were terminated at the selection and implementation hearing.

Most of the issues presented here continue to be routinely raised in dependency appeals, even though this court has consistently rejected them in a host of unpublished opinions. Parents’ arguments, preserved by computer technology, have nonetheless taken on an electric life of their own in brief after brief. We publish this opinion in an effort to short-circuit them once and for all.

I

Jill remarkably asserts the juvenile “court made no finding that [she] was an unfit mother . . . [and] basically terminated [her] parental rights based only on findings that [the dependent minor] was adoptable.” This contention is belied by the record. Statutory findings of detriment were made at every stage of the proceedings, and they are not challenged.

Nevertheless, relying on Santosky v. Kramer (1982) 455 U.S.…