San Diego County Health & Human Services Agency v. Jennifer M.

Jennifer M. appeals a juvenile court order terminating her reunification services as to her minor daughter, Katelynn Y, under Welfare and Institutions Code section 388, subdivision (c)(1)(B), 1 which allows for early termination of services if the inaction of a parent creates a substantial likelihood reunification will not occur. Jennifer contends the court erred, as a matter of law, by terminating her services when Katelynn’s father, Christopher Y, was still receiving services with the goal of reunification, and the court did not set a section 366.26 selection and implementation hearing. Alternatively, Jennifer contends the court abused its discretion by terminating her reunification services while offering services to Christopher. We affirm the order.

FACTUAL AND PROCEDURAL BACKGROUND

Jennifer and Christopher (together, the parents) each have a history of methamphetamine use and domestic violence. In December 2010, the San Diego County Health and Human Services Agency (Agency) received a referral that Jennifer left five-year-old Katelynn with the maternal grandmother for 12 days, and the parents’ whereabouts were unknown. Jennifer *875 had relapsed on drugs and said…