In re G.S. CA1/1

BACKGROUND

Proceedings Before Section 366.26 Hearing The juvenile court took jurisdiction of then-one-year-old G.S. (minor) and removed her from mother’s care, after mother admitted, and the court sustained, allegations that minor was at a substantial risk of harm and neglect in that “there have been multiple instances of domestic violence . . . between the mother . . . and [father], in the presence of the children”3 and that “mother has allowed [father] to continue to reside in the home, despite [an] active restraining order, placing the children at substantial risk of serious harm.” At the disposition hearing, the court adopted the Contra Costa County Children and Family Services Bureau’s (Bureau) recommendations of continued services and visitation. Over the next 18 months, the Bureau recommended terminating services to mother. Despite mother’s lack of compliance with her case plan, the juvenile court extended services due in part to extending services to father and because of the lack of in-person visits due to the pandemic. At the 18-month hearing, the court stated, “despite previously making . . . generous accommodations and . . . extending services to the 18 months, which…