Orange County Social Services Agency v. Laura R.

Amanda C., de facto parent, and Lauren R., the minor, appeal from the juvenile court’s order removing Lauren from Amanda’s home and placing her for adoption by her maternal aunt, Yelda C., who lives in Oregon. Using the factors designated for a temporary relative placement (Welf. & Inst. Code, § 361.3, subd. (a)), 1 the juvenile court found Yelda was the better placement. We find the relative placement preference did not apply to the placement order because (1) no new placement was necessary and (2) it was a placement for adoption. Because the placement- order was for adoption, we find the caretaker preference (§ 366.26, subd. (k)) was applicable. Accordingly, we remand tire case for consideration under the proper statute.

I

FACTS

Lauren R. is 10 years old. She was made a dependent of the juvenile court in Oregon, where her family lived, early in her childhood. The family moved to Orange County when Lauren was five years old. About a year later, she *846 was made a dependent of the Orange County Juvenile Court due to her parents’ substance abuse and domestic violence, as well as their failure to protect her from sexual abuse. After 18 months out of her parents’…