Los Angeles County Department of Children & Family Services v. Susan S.

Introduction

Mother, Susan S., appeals from the order terminating her parental rights over Vincent S. (Welf. & Inst. Code, 1 § 366.26.) We hold that the court committed procedural error because California Rules of Court, rule 1463(a) prohibits the juvenile court from terminating the rights of one parent at a time. However, because the parental rights of father, Charles C., were terminated in a later proceeding and father abandoned his appeal of that order, the error was harmless. Accordingly, we affirm the order.

Factual and Procedural Background

Mother has a history of drug use and contacts with law enforcement. Father was incarcerated and has had no contact with the child. On February *1092 12, 1999, mother left then two-month-old Vincent in a parked car while she entered a store. Mother was arrested after attempting to exchange for a cash refund merchandise she had not purchased. At the time, she possessed an altered driver’s license.

Vincent was declared a ward of the court pursuant to section 300, based on a petition which alleged that mother placed the child in an endangering situation, was incarcerated, tested positive for methamphetamine, and had another child…