Santa Clara County Department of Family & Children's Services v. Debbie W.

Debbie W. appeals from an order terminating her parental rights over her daughter, Brittany C. (Welf. & Inst. Code, § 366.26.) 1 Appellant contends that the juvenile court erred: (1) in its interpretation of section 366.26, subdivision (c)(1)(A); and (2) in its retroactive application of section 366.26, subdivision (c)(4). For the reasons stated below, we affirm.

Statement of Facts

Appellant has five children. Brittany, who was born on July 15, 1991, is her third child. Brittany and her half siblings, Michael B. and Anastasia B., became the subjects of a dependency action on February 6, 1997. When *849 appellant was in the hospital for the birth of Michael in January 1997, she told hospital staff that she had used methamphetamine and alcohol during her pregnancy. Appellant also acted as if she were under the influence of an illegal substance while she was in the hospital. The Voluntary Family Reunification Program of the Santa Clara County Department of Family and Children’s Services (Department) offered her services after her release. However, appellant missed appointments with the social worker, and she appeared to be under the influence when she did attend…