In re R.G. CA4/1

INTRODUCTION

Denise D. (Denise) and Richard G. (Richard) appeal the juvenile court's order

terminating their parental rights to their son, R.G., pursuant to Welfare and Institutions

Code section 366.26. (Further statutory references are to the Welfare and Institutions Code.) Denise also appeals the juvenile court's order denying her petition for

modification under section 388, asking that R.G. be placed with her, or alternatively, that

she be granted further reunification services.

We conclude the juvenile court abused its discretion in denying Denise's section

388 petition and, accordingly, reverse that order. In view of that conclusion, we need not

address the parents' other arguments challenging the trial court's order terminating their

parental rights under section 366.26. (In re Jeremy W. (1992) 3 Cal.App.4th 1407, 1416

["In the chronology of these events, a fair hearing on the section 388 petition was a

procedural predicate to proceeding to the section 366.26 hearing and disposition."]; In re

Lauren R. (2007) 148 Cal.App.4th 841, 861 (Lauren R.) ["Because it is necessary to

restore all parties to their prior positions, the orders…