Sacramento County Department of Health & Human Services v. Michelle R.

Michelle R. and Derrick E. (appellants), the parents of Raymond E. (the minor), appeal from an order of the juvenile court terminating their parental rights. 1 Appellants claim the court erred when it failed to find that it would be detrimental to the minor to sever their relationship with him. Michelle separately claims that the court erred when it failed to properly consider the effect of adoption on the minor’s relationship with his brother. We disagree and will affirm the order terminating parental rights.

Effective January 1, 2002, the Legislature amended section 366.26, subdivision (c)(1), creating an additional exception to the termination of parental rights upon a finding of adoptability. Under new subdivision (c)(1)(E), *615 the juvenile court may find a compelling reason for determining that termination of parental rights would be detrimental to the minor where “[tjhere would be substantial interference with a child’s sibling relationship, taking into consideration the nature and extent of the relationship, including, but not limited to, whether the child was raised with a sibling in the same home, whether the child shared significant common experiences or has…