In re David C. CA2/1

BACKGROUND

Because the sole issue in this appeal is whether the beneficial relationship exception applied, we confine our factual and procedural summary to that issue and begin by describing the basic legal principles necessary to give that summary context.

1 Further unspecified statutory references are to the Welfare and Institutions Code. Mother’s notice of appeal included the juvenile court’s denial of her section 388 petition. Mother did not make any arguments concerning this denial in her appellate briefs and thus has forfeited the issue. (See In re Adrian L. (2022) 86 Cal.App.5th 342, 344, fn. 1 [although notice of appeal included appeal from order denying section 388 petition, parent forfeited any claim of error where opening brief presented no argument on that issue].)

2 A. Applicable Legal Principles When a juvenile court cannot safely return a child to a parent’s custody, the court must set a permanency planning hearing under section 366.26. (In re Caden C. (2021) 11 Cal.5th 614, 630 (Caden C.).) “ ‘ “[A]t a section 366.26 hearing, the court may select one of three alternative permanency plans for the dependent child—adoption, guardianship or long-term foster…