In re A.H. CA2/4

INTRODUCTION

A. A. (Mother) is the birth mother of A. H. (the child), and the daughter of Nichole R. (maternal grandmother). On March 14, 2012, at a Welfare and 1 Institutions Code section 366.26 hearing, the juvenile court terminated Mother’s parental rights. At the same hearing, the court denied the maternal grandmother’s petition under section 388 to have the child placed with her. Mother appeals from both orders of the juvenile court. She contends (1) that she has standing to challenge the denial of the maternal grandmother’s section 388 petition, (2) that the juvenile court erred by failing to provide the maternal grandmother with a full evidentiary hearing on the section 388 motion, and (3) that the decision to terminate her parental rights should be reconsidered de novo on remand. Finding no error, we affirm.

FACTUAL AND PROCEDURAL HISTORY

In 2009, Mother, then 16, lived with the maternal grandmother. In June 2009, the maternal grandmother left for an urgent trip to Texas. She took the year old child with her, and left Mother at home with Mother’s 14-year-old godsister. During the three day trip, Mother did not maintain communication with the maternal grandmother, failed…