San Diego County Health & Human Services Agency v. Angela G.

Angela G. and Erick O. appeal orders terminating their parental rights under Welfare and Institutions Code section 366.26. (Unless otherwise indicated, further references are to the Welfare and Institutions Code.) They contend the juvenile court erred when it found that their son, Michael, was likely to be adopted within a reasonable time if parental rights were terminated. The parents argue the social services agency’s adoption assessment report was inadequate, and the court should have granted a brief continuance to allow the social worker time to receive an updated report from Michael’s therapist and the results of Michael’s court-ordered psychological evaluation, and to further assess his adoptability in the context of that information. The parents also argue there is insufficient evidence to support the findings that the beneficial parent-child and sibling relationship exceptions to termination of parental rights did not apply. We affirm the findings and orders.

*584 We conclude that the juvenile court erred when it did not order a brief continuance of the section 366.26 hearing to allow time to receive Michael’s psychological evaluation and an updated report from…