Sacramento County Department of Health & Human Services v. Sonya C.

The mother, Sonya C. (mother), appeals the juvenile court’s order terminating her parental rights to T.C. Mother contends that because the permanent plans for two-year-old T.C. and her almost 13-year-old half sister, R.B., were different, an actual conflict arose for the minor’s counsel and the trial court prejudicially erred in not recognizing this conflict and appointing separate counsel. We shall affirm.

FACTUAL AND PROCEDURAL BACKGROUND

The minor T.C., then two months old, and her half sister R.B., then 11 years old, were detained in December 2008 due to mother’s ongoing drug use and untreated mental health problems. They were placed together in a foster home and, a few days later, moved together to live with a nonrelated extended family member. In March 2009, T.C. was declared a dependent based on mother’s mental health problems, drug use, and domestic violence between mother and T.C.’s father. R.B. was declared a dependent on the same basis in June 2009. Reunification services were ordered.

Throughout the proceedings, R.B. and T.C. continued to live together. R.B. was adjusting well and T.C. was “doing great.” It appeared that R.B. had taken a caretaking role…