A.B.

A.A., the minor, was removed from his mother’s custody in 2008 when she was arrested on a federal warrant and was placed in his father’s custody, with reunification services for the mother (mother). While mother was still imprisoned, the court terminated dependency jurisdiction, awarding custody to the father (father). However, a month later, the dependency was reactivated based on new allegations that the minor was physically abused by father, while mother was still serving her federal sentence. This time the court authorized services for father, but not mother. When father failed to reunify, services were terminated and the matter was set for a hearing to select and implement a permanent plan of adoption. (Welf. & Inst. Code, 1 § 366.26.) Mother filed a request to modify the order denying her services (§ 388), which was heard and denied at the section 366.26 hearing, and the juvenile court proceeded to terminate parental rights. Mother appealed.

*602 On appeal, mother asserts (1) her constitutional rights were violated when the court did not consider placing A.A. in her custody at the disposition hearing on the subsequent petition pursuant to section 361.2, and (2)…