In re Aaron R. CA2/4

INTRODUCTION

Aaron R. (born Dec. 2015) was declared a dependent of the juvenile court in February 2020, when the court sustained a petition in which respondent Los Angeles County Department of Children and Family Services (DCFS) alleged that mother and father had a history of engaging in violent altercations in Aaron’s presence. In November 2019, DCFS removed Aaron from mother’s home and placed him in the home of relatives. The court ordered family reunification services but terminated them a year later and set a permanency planning hearing. At that hearing (in Sept. 2021), it was undisputed that the relatives would likely adopt Aaron. (See In re Caden C. (2021) 11 Cal.5th 614, 630 (Caden C.).) Mother, however, asserted the “beneficial parental relationship exception” to termination of parental rights. (Ibid.) The juvenile court rejected the exception and terminated mother’s parental rights. On appeal, mother contends the juvenile court erred when it did not apply the beneficial parental relationship exception.1 We disagree and affirm.

FACTUAL AND PROCEDURAL BACKGROUND

A. Relevant Events Leading to the Permanency Planning Hearing On September 29, 2019, DCFS received a referral…