In re H.E. CA4/1

INTRODUCTION

S.E. (Mother) appeals from the juvenile court’s order terminating her parental rights to H.E., her then 20-month-old daughter. (Welf. & Inst. Code,

§ 366.26.)1 She contends the juvenile court erred in finding the parental- benefit exception to adoption did not apply. (§ 366.26, subd. (c)(1)(B)(i).) Because we conclude Mother has not affirmatively demonstrated error, we affirm the juvenile court’s order terminating Mother’s parental rights.

FACTUAL AND PROCEDURAL BACKGROUND

In September 2019, Mother was arrested after she was found driving under the influence of methamphetamine and cocaine, with then two-month- old H.E. unrestrained on her lap. Earlier, Mother had called 911 to report she was experiencing hallucinations. Witnesses also recounted seeing Mother squeezing H.E.’s neck and holding her tightly to her chest. Mother had an extensive history of mental health issues and substance abuse, and was receiving voluntary services from the San Diego County Child Welfare

Services Agency (Agency) the two months prior to her arrest.2 The Agency filed a petition under section 300, subdivision (b)(1), alleging that Mother’s substance abuse and mental illness rendered…