Sacramento County Department of Health & Human Services v. Sandra S.

Sandra S. (appellant), the mother of Dakota S. (the minor), appeals from orders of the juvenile court modifying the minor’s placement and selecting a permanent plan of guardianship with the minor’s foster parent, who had been given de facto parent status. (Welf. & Inst. Code, §§ 366.26, 388; further section references are to this code unless specified otherwise.) Among other things, appellant claims that the orders must be reversed because the Sacramento County Department of Health and Human Services (DHHS) did not prepare, and the juvenile court did not consider, an assessment of the foster parent as the prospective guardian.

In the published portion of this opinion, we observe that DHHS failed to comply with its statutory obligation to submit a preliminary assessment of the foster parent’s eligibility, commitment, and suitability as a prospective guardian. (§ 366.22, subd. (b).) We do not take this omission lightly. After all, the purpose of the assessment is to provide the juvenile court with information necessary to determine whether guardianship is in the dependent child’s best interests, and whether the prospective guardian is an appropriate person to assume the…