In re C.Z. CA4/1

I.

INTRODUCTION

A.Z. (Father), L.B. (Mother), and W.R. and L.R. (collectively, the Relatives) appeal orders denying the Relatives’ petition to change minor C.Z.’s placement, terminating parents’ parental rights, and selecting a permanent plan of adoption for C.Z. They generally contend that the trial court erred in failing to apply the statutory preferential consideration of relatives for placement pursuant to Welfare and Institutions Code section

361.3.1 The Relatives contend that their due process rights were violated because they were not provided with proper notice of their right to seek placement at an earlier point in this proceeding. They contend that for these reasons, the juvenile court’s orders must be reversed. Appellants have failed to establish any reversible error. Although the Relatives should have received written notice early in the proceeding and did not, the proper remedy for a failure to provide notice would be a hearing before the juvenile court to consider a change in placement under the factors set forth in section 361.3. In this case, after the Relatives specifically requested such a hearing, the juvenile court conducted a hearing, applying the section…