Santa Clara County Department of Family & Children's Services v. Patricia J.

Appellants Patricia J. (the mother) and Angelina J. challenge the juvenile court’s termination of the mother’s parental rights to her son Bailey J., Angelina’s half sibling, and the court’s selection of adoption as Bailey’s permanent plan. The mother contends that the juvenile court erred in failing to apply the parental relationship exception to adoption and/or the sibling relationship exception to adoption. Angelina maintains that the juvenile court prejudicially erred in refusing to accord her status as a party at the Welfare and Institutions Code section 366.26 1 hearing and in failing to apply the sibling relationship exception to adoption. We reject their contentions and affirm the juvenile court’s order.

I. Background

In 2004, long before Bailey was bom, two of Bailey’s siblings, one of whom was one year old and the other of whom was one month old, and two of his half siblings, six-year-old Angelina and her eight-year-old half brother, were removed from the custody of the mother and the father. Bailey’s two siblings had suffered multiple bone fractures as infants, and the parents were found to have physically abused them. The mother and the father failed to…