Opinion
E053125 Super.Ct.No. J223316
09-06-2011
In re I.G., a Person Coming Under the Juvenile Court Law. SAN BERNARDINO COUNTY CHILDREN AND FAMILY SERVICES, Plaintiff and Respondent, v. J.L. et al., Defendants and Appellants.
Matthew I. Thue, under appointment by the Court of Appeal, for Defendant and Appellant E.G. Jesse McGowan, under appointment by the Court of Appeal, for Defendant and Appellant J.L.
NOT TO BE PUBLISHED IN OFFICIAL REPORTS
California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.
OPINION
APPEAL from the Superior Court of San Bernardino County. Barbara A. Buchholz, Judge. Affirmed.
Matthew I. Thue, under appointment by the Court of Appeal, for Defendant and Appellant E.G.
Jesse McGowan, under appointment by the Court of Appeal, for Defendant and Appellant J.L.
Jean-Rene Basle, County Counsel, and Danielle E. Wuchenich and Kristina Robb, Deputy County Counsel, for Plaintiff and Respondent.
I. INTRODUCTION
Defendant and appellant E.G. (Mother) appeals from an order terminating her parental rights concerning her daughter, I.G., pursuant to section 366.26 of the Welfare and Institutions Code. Mother contends the termination of her parental rights therefore violated her right to due process because there was no evidence she was an unfit parent. As we explain below, we reject this argument.
All further statutory references are to the Welfare and Institutions Code unless otherwise indicated.
Defendant and appellant J.L. (alleged Father), an alleged father of I.G., also appeals. He joins in and adopts Mother's arguments, and argues that if we reverse the order terminating parental rights, the court must also reinstate his parental rights.Because we reject Mother's argument, alleged Father's argument also fails.
Alleged Father's notice of appeal states he is appealing from the order terminating parental rights and from an order denying his request for a paternity test. He does not make any argument in his brief concerning a paternity test. Accordingly, we treat the appeal on that point abandoned. (See Reyes v. Kosha (1998) 65 Cal.App.4th 451, 466, fn. 6; Wurzl v. Holloway (1996) 46 Cal.App.4th 1740, 1754, fn. 1.)
We affirm the orders terminating parental rights.
II. SUMMARY OF FACTS AND PROCEDURAL HISTORY
A. Background
During an altercation with a friend in August 2008, Mother allegedly grabbed the friend's two-year-old child and pushed him to the ground. Mother was arrested for being under the influence of a controlled substance and child endangerment. Social workers with the San Bernardino County Children and Family Services (CFS) removed I.G. from Mother's custody and placed her in foster care. I.G. was 10 months old at the time. Mother reported that alleged Father is I.G.'s father and said he "is [nowhere] to be found."
Formerly known as the San Bernardino County Department of Children's Services.
In addition to I.G., Mother has a two-year-old son who lives with Mother's estranged husband. The husband denied that he is I.G.'s father and was declared a nonparty as to I.G.
At a detention hearing, the court found a prima facie case had been established for detaining I.G. outside of the home. I.G. would remain in foster care. The court ordered twice weekly visits between Mother and I.G. The court also ordered Mother to submit to drug testing.
CFS filed a juvenile dependency petition concerning I.G. under section 300, subdivisions (b) (failure to protect) and (g) (no provision for support). Under subdivision (b), CFS alleged that Mother has a history of substance abuse that impairs her ability to provide adequate care and supervision for I.G., and that alleged Father failed to provide for the child's basic needs. Under subdivision (g), CFS alleged that Mother is incarcerated and that alleged Father's whereabouts and his ability to provide financial assistance are unknown. (Other allegations were subsequently stricken.)
At the jurisdictional/dispositional hearing, the court found these allegations true and declared I.G. to be a dependent of the court. The court found, by clear and convincing evidence, that there was substantial danger to I.G.'s health, safety, or well-being—or would be if she was returned home. The court ordered supervised visits at least once per week. Reunification services were ordered for Mother and denied for alleged Father. Mother did not appeal from the dispositional orders.
In a six-month status review report, the social worker reported that Mother "has been clean and sober for a period of 202 days," cooperative in her program and with the social workers, and is motivated to get her children back. Mother said she is working on returning to college to gain marketable skills and secure employment. The social worker said that Mother was "compliant" and not "under the influence" during visits. In the social worker's assessment, "although [Mother] continues to work hard at completing her case plan goals she has encountered great difficulty," and her "ability to meet the basic needs of [I.G.] are not proven at this time." The social worker believed Mother would benefit from an additional six months of services.
At the six-month review hearing held in April 2009, the court found by a preponderance of the evidence that returning I.G. to Mother's custody would create a substantial risk of detriment to the safety, protection, or physical or emotional well-being of the child. The court ordered Mother to undergo a psychological evaluation. It also ordered continued reunification services for Mother.
In the next status report, the social worker reported that Mother has maintained her sobriety for 413 days. Since the last report, Mother was incarcerated for 90 days for a probation violation. Upon discharge, she contacted the drug court coordinator to continue in the program. The report incorporated a psychological evaluation. The psychologist described Mother as "socially immature, with a misunderstanding about appropriate social norms." "She demonstrated difficulty with her processing ability, conceptual thought process, and overall cognitive ability . . . ." She also "demonstrates symptoms of suspiciousness and paranoia . . . ." In the prognosis section of the report, the psychologist stated that Mother "does not demonstrate Axis II difficulties that would impair her ability to parent her children or result in her inability to benefit from mental health services. [¶] [She] is seen as willing and able to engage in services recommended for her. However, it should be noted that she is limited in her cognitive and academic skills, and therefore, treatment recommendations are geared toward someone at this level of ability." The psychologist recommended ongoing placement in a sober living house and a female sponsor to provide support and hold her accountable for her sobriety. The psychologist also recommended that Mother attend at least one 12-step meeting every day for 90 days, continued psychotherapy, group psychotherapy, and a psychiatric medication evaluation.
The social worker reported that Mother has enrolled in two drug rehabilitation programs and has shown great difficulty processing and benefiting from the programs. The report described behaviors that caused problems with Mother's ability to complete drug programs. When she "created a rift" with the staff of her sober living facility, she left the facility and became homeless. She "continues to exhibit paranoid type behavior when she is visiting with [I.G.] [She] continues to accuse everyone that comes in contact with [I.G.] of 'molesting' [I.G.] At [I.G.'s] recent birthday . . . held at the church, [Mother] attempted to undress the child in front of the guests because she stated that she smelled funny 'like booty.'" She also stated that I.G. had "head lice" and "ma[d]e a scene." A subsequent examination showed that I.G. did not have head lice.
At a subsequent hearing, Mother was asked whether she attempted "to undress [I.G.] in front of people at a birthday party because [she] thought that her bootie smelled[.]" Mother said that this was false.
In their assessment and evaluation of Mother, the social worker stated that although Mother is "personable and pleasant," it is clear that her "mental health issues impair[] her ability to safely have [I.G.] in her care and custody." She "cannot demonstrate that she has benefited from her services." In the social worker's view, returning I.G. to Mother "would create a substantial risk of detriment to the physical and emotional well being of the child."
At the 12-month review hearing held in December 2009, the court found that custody by Mother would be detrimental to I.G. and would create a substantial risk of detriment to I.G.'s physical and emotional well-being. The court further found, by clear and convincing evidence, that Mother has failed to make substantive progress in the court-ordered treatment plan.
In January 2010, Mother began participating in psychotherapy with Dr. Kenneth Meyer, but discontinued after five sessions when she moved to Orange County. Dr. Meyer stated that "the prognosis for [Mother] is good, but only if she completes a course of psychotherapy and continues in her sobriety. In [his] professional opinion it is going to take time for her to change the dynamics of her behavior and personality structure so she may become a fully functioning person." B. Eighteen-month Review and Termination of Reunification Services
In February 2010, the social worker recommended that reunification services be terminated and a section 366.26 hearing be set. According to the report, Mother has supervised visits with her children twice each week. Other than noting that Mother favors I.G. over her older son, the social worker did not report any problems with Mother during visits. The social worker reported that Mother has maintained her sobriety for more than one and one-half years. However, the social worker stated that Mother "continues to exhibit behaviors that are of great concern and continue to require [CFS] intervention." It was noted that she was dismissed from drug court after she went to Nevada in violation of the program's rules and did not return on time, and has failed to look for work. Although she had completed the goals and objectives of her case plan, "she has not been able to exhibit knowledge that she has benefited from the services that [CFS] has provided her."
The primary concern expressed by the social worker was that "[M]other had some cognitive impairment and possible mental health concerns that impaired her ability to benefit from the programs that she was attending." The social worker concluded: "With the cognitive and mental health difficulties[] that [M]other is currently[] experiencing[,] it is in the best interest of the child to establish a more permanent plan. Mother has entered a new Christian based program and if she is able to remain in this program for at least six months and continue with her therapeutic interventions that she maybe [sic] able to parent her child without further intervention of [CFS]." The social worker recommended that the permanent plan to be decided at the section 366.26 hearing not be limited to adoption.
At an 18-month review hearing held in May 2010, Mother testified that she is in therapy with a new therapist, has been "clean" since August 2008, and is making the right decisions because of her sobriety. She said she has completed classes in parenting, anger management, domestic violence, relapse prevention, and recovery skills, among others. She explained why she was kicked out of the drug court program: She had been given a pass to visit her sister in Los Angeles; but when she went to Los Angeles she learned that her sister was in Reno, Nevada; so she went there without first getting a pass to go out of state. She is living at the Orange County Rescue Mission.
The social worker assigned to Mother's case testified that her "primary concern is [Mother's] ability to effectively parent without the support of individuals and agencies." When asked about Mother's completion of the "technical aspects" of her case plan, the social worker explained: "Clients are given service plans, and they are given goals and objectives to complete. However, it's more than just a checklist. What the Department looks at and what I look at is whether parents have benefitted from any of the services that they've been provided." In her opinion, because Mother has not resolved her mental health issues, I.G. would be at risk if returned to Mother's care. She also expressed concern about Mother's transient history and inability to maintain a stable residence.
The court found by clear and convincing evidence that Mother has failed to participate regularly in and to make substantive progress in the court-ordered treatment plan. The court further found, by a preponderance of evidence, that custody by Mother continues to be detrimental to I.G., I.G.'s welfare and best interests require that custody continue to be taken from Mother, and returning I.G. to Mother at this time would create a substantial risk of detriment to I.G.'s physical and emotional well-being. The court terminated reunification services and set a hearing to be held pursuant to section 366.26.
Mother was informed of her right to file a writ petition pursuant to rule 8.452 of the California Rules of Court. Mother filed a notice of intention to file a writ petition, but subsequently informed this court that she would not do so. C. Section 388 Petition and Section 366.26 Hearing
Alleged Father was not present at the hearing. Notice of his right to file a writ petition was sent to his last known address and later returned undelivered.
Alleged Father was present in court for the first time in the case in September 2010, at the initial hearing scheduled for the section 366.26 hearing. Through counsel, alleged Father requested a paternity test. The court denied the request. The court continued the section 366.26 hearing.
Mother filed a request to change order pursuant to section 388. She sought an order reinstating reunification services and "liberaliz[ing]" visits with I.G. She asserted that she completed a parenting class and a money management class, and is participating in a 12-step recovery class. She has also been sober for two years. She claimed the change would benefit I.G. because she has regularly visited I.G. and looks forward to the time she spends with her, and she "expect[s] that [I.G.] does as well." The court set a hearing on the request.
CFS filed a response to the request to change order which describes how Mother's behavioral issues has resulted in her termination from drug programs and sober living housing. Mother, the social worker explained, has "some cognitive impairment and possible mental health concerns that impaired her ability to benefit from the programs that she was attending." The social worker referred to the reports of psychologists which indicate that Mother's social development is stunted at the age of a 12 year old, and that she has severely impaired judgment and poor insight. While acknowledging that "[M]other has worked to complete the goals and objectives on her Family Reunification Case Plan," the social worker concluded that "she has not been able to exhibit knowledge that she has benefited from the services that [CFS] has provided her." Regarding the interest of the child, the social worker stated: "Because of cognitive and mental health difficulties[] that [M]other has been diagnosed with and continues to experience[,] it is in the best interest of [I.G.] to establish a more permanent plan." They recommended adoption with I.G.'s current caregiver, with whom the child "has a significant bond of over two years."
Following an evidentiary hearing, the court denied the request for change order. The court expressly recognized that Mother had made significant progress over time and that Mother loved I.G. "as truly a mother would love a child." The court also acknowledged that Mother has remained sober and has participated in the services offered at her current facility. However, the court found that Mother had not completed a course of psychotherapy, as Dr. Meyer had recommended, nor had she shown that she can function outside of a sober living facility and take sole responsibility for her sobriety. More importantly, the court found that the requested change would not be in the best interests of the child. In particular, the court noted that I.G. had been with Mother from infancy until she was 11 months old, and has been with her caretaker for the last two and one-half years. The court concluded that while "[M]other has made significant progress and clearly has made a lot of effort towards reaching her goal[, the] court just does not find that change[d] circumstances exist[] or that it's in the best interest of the minor."
The court then proceeded to the section 366.26 hearing. The court considered the evidence presented at the hearing on the section 388 petition and admitted certain social worker reports into evidence. No additional evidence was offered. Following argument, the court found by clear and convincing evidence that it was likely I.G. would be adopted and terminated the parental rights of Mother and alleged Father.
III. ANALYSIS
Mother contends the court erred in terminating her parental rights because there was no evidence she was an unfit parent. She contends that a finding of parental unfitness, supported by clear and convincing evidence, is required under the due process clause of the Fourteenth Amendment and Santosky v. Kramer (1982) 455 U.S. 745. As Mother acknowledges, California's dependency law does not require a finding of parental unfitness at the section 366.26 hearing when termination of parental rights is contemplated. As our state Supreme Court explained: "Unlike the termination hearings evaluated in Santosky v. Kramer, supra, 455 U.S. 745, . . . the purpose of the section 366.26 hearing is not to accumulate further evidence of parental unfitness and danger to the child, but to begin the task of finding the child a permanent alternative family placement. By the time dependency proceedings have reached the stage of a section 366.26 hearing, there have been multiple specific findings of parental unfitness. Except for a temporary period, the grounds for initial removal of the child from parental custody have been established under a clear and convincing standard [citation]; in addition, there have been a series of hearings involving ongoing reunification efforts and, at each hearing, there was a statutory presumption that the child should be returned to the custody of the parent. [Citations.] Only if, over this entire period of time, the state continually has established that a return of custody to the parent would be detrimental to the child is the section 366.26 stage even reached." (Cynthia D. v. Superior Court (1993) 5 Cal.4th 242, 253, italics added, fn. omitted.) Not only is a finding of parental unfitness not required at the section 366.26 hearing, "the critical findings of parental unfitness, detriment, and the failure of attempts at reunification may not be reopened or reconsidered at the termination hearing . . . ." (In re Zeth S. (2003) 31 Cal.4th 396, 411.)
"California's dependency scheme no longer uses the term 'parental unfitness,' but instead requires the juvenile court make a finding that awarding custody of a dependent child to a parent would be detrimental to the child." (In re P.A. (2007) 155 Cal.App.4th 1197, 1211.) Detriment is "an infinitely more precise concept" than unfitness because it "ensures the juvenile court's focus is properly centered on the absence or breakdown of a relationship between a particular parent and a particular child." (In re Cody W. (1994) 31 Cal.App.4th 221, 225.) "Unfitness," on the other hand, "can suggest an individual is not a proper parent under any circumstances" (ibid., fn. omitted) and does not account for "the unique circumstances" of the particular parent-child relationship (In re Dakota H. (2005) 132 Cal.App.4th 212, 224, fn. 3). A detriment finding is essentially equivalent to an unfitness finding, for purposes of the parent's due process rights. (See In re Jasmon O. (1994) 8 Cal.4th 398, 423.)
Mother does not dispute these principles or contend the juvenile court failed to make findings of detriment whenever they were statutorily required. She contends, however, that even when such findings are made, they "do not always develop into clear and convincing evidence of parental unfitness" required by the Constitution. She relies heavily on In re P.C. (2008) 165 Cal.App.4th 98 (P.C.) and In re G.S.R. (2008) 159 Cal.App.4th 1202 (G.S.R.). Both are distinguishable from the present case.
G.S.R. involved a noncustodial father, Gerardo, who was declared the presumed father of his two sons shortly after the detention hearing. (G.S.R., supra, 159 Cal.App.4th at p. 1206.) The boys were taken into protective custody after their mother was arrested for having sex with a minor. (Id. at p. 1205.) No section 300 allegations were alleged or proved against Gerardo, and he was proclaimed to be "nonoffending." (G.S.R., supra, at p. 1207.) Gerardo participated in court-ordered services, including Alcoholics Anonymous meetings, and he visited with and sought custody of his sons, but was never able to obtain affordable housing that could accommodate them. (Id. at pp. 1206-1207.) At the review hearings, the court determined it would be detrimental to place the boys with Gerardo. (Id. at pp. 1207-1208.) At the section 366.26 hearing, Gerardo argued his due process rights would be violated if his parental rights were terminated because he was a nonoffending parent who had never been found unfit. (G.S.R., supra, at p. 1209.) The juvenile court rejected Gerardo's claim and terminated his parental rights. (Id. at pp. 1209-1210.)
On appeal, the court concluded that the juvenile court violated Gerardo's due process rights by terminating his parental rights without ever having found he was an unfit parent. (G.S.R., supra, 159 Cal.App.4th at pp. 1211-1212.) The court pointed out that Gerardo had always been involved in his sons' lives and had provided them with financial support even when he was homeless. (Id. at p. 1212.) Moreover, the court reasoned that the record "strongly suggest[ed] the only reason Gerardo did not obtain custody of the boys was his inability to obtain suitable housing for financial reasons. But poverty alone, even abject poverty resulting in homelessness, is not a valid basis for assertion of juvenile court jurisdiction." (Ibid., fn. omitted.) The court also pointed out that section 300, subdivision (b) expressly states: "'[N]o child shall be found to be a person described by this subdivision solely due to the lack of an emergency shelter for the family. . . .' Put differently, indigency, by itself, does not make one an unfit parent . . . ." (G.S.R., supra, at p. 1212.)
The court in G.S.R. further concluded that the evidence was insufficient to support the juvenile court's various detriment findings, principally because Gerardo's poverty and lack of suitable housing for his sons was an insufficient reason to conclude he was incapable of parenting them, and the agency never made any effort to assist Gerardo in obtaining affordable housing. (G.S.R., supra, 159 Cal.App.4th at pp. 1213-1214.) The court reversed the termination order and remanded the matter to the juvenile court to determine whether there were any legally sufficient grounds, at the time of remand, to find it would be detrimental to return the boys to Gerardo. (Id. at p. 1215.)
In P.C., the court took G.S.R. one step further in reversing a termination order for an "offending" parent who had complied with her case plan and did everything she could do to regain custody of her children but who, like Gerardo in G.S.R., was unable to obtain affordable housing for her children. The court framed the issue as whether the mother's "poverty alone" or her inability to obtain suitable housing for her children was a sufficient ground to deprive the mother of her parental rights to her children. (P.C., supra, 165 Cal.App.4th at pp. 99, 103.) By the time of the 18-month review hearing, the mother had completed her case plan and the social worker testified that her lack of suitable housing was the only reason the children could not be returned to her care. (Id. at p. 101.) Still, the juvenile court terminated the mother's services and found by clear and convincing evidence that returning the children to her care "'would create a substantial risk of detriment'" to their "'physical and emotional well-being.'" (Id. at p. 102.) Then, at the section 366.26 hearing, the social worker testified that the mother's "inability to obtain suitable housing" was the only reason the agency was recommending the children be adopted. (P.C., supra, at p. 102.)
At the jurisdictional hearing in P.C., the juvenile court sustained allegations that the mother had physically abused her children, the father had committed acts of domestic violence against the mother, and the mother had left the children with a caretaker without means of support, knowledge of the mother's whereabouts, or the time of her return. (P.C., supra, 165 Cal.App.4th at p. 100.)
In reversing the termination order, the P.C. court found G.S.R. "on point" because, like Gerardo in G.S.R., the mother's inability to obtain suitable housing was the only basis for the juvenile court's detriment findings. (P.C. supra, 165 Cal.App.4th at p. 106.) The court pointed out that if the mother had not completed her case plan and corrected her behavior that led to the children's dependency, it would have agreed that the detriment findings were "tantamount to a finding of parental unfitness." (Ibid.) But because the mother had completed her case plan, corrected her behavior, and the social worker had not reasonably assisted her in obtaining suitable housing, the court concluded the juvenile court's detriment findings, and its findings the agency had provided or offered reasonable services to the mother, were not supported by substantial evidence. (Ibid.)
Initially, we note that G.S.R. is easily distinguished from this case because Gerardo (the father in G.S.R.) was a nonoffending, noncustodial parent against whom no jurisdictional allegations were asserted or sustained. (G.S.R., supra, 159 Cal.App.4th at pp. 1210-1211.) Nor does the opinion indicate that the court ever made a detriment finding based on clear and convincing evidence. In short, "no judicial finding of a lack of parental fitness was made . . . ." (Id. at p. 1211.) Here, by contrast, Mother was I.G.'s custodial parent at the time of removal and the parent against whom the court sustained a section 300 allegation based on failure to protect I.G. She was therefore an "offending" parent. Moreover, the court expressly found by "clear and convincing evidence" that I.G. "should be removed from the physical custody of the parents in that there is a substantial danger to the physical health, safety, protection, or physical or emotional well-being of [I.G.,] or would be if [I.G.] were returned home, and there are no reasonable means by which [I.G.'s] physical health can be protected without removing [I.G.] from the parents' physical custody." Mother does not dispute the jurisdictional determination or the detriment finding on appeal. In addition, the court expressly found at the status review hearings that returning I.G. to Mother's custody would create a substantial risk of detriment to the child. G.S.R., therefore, does not apply here.
Although the question has not been briefed, it appears that any challenge to the jurisdictional and dispositional findings have been waived or forfeited by failing to appeal from the dispositional order. (See In re S.B. (2009) 46 Cal.4th 529, 532; In re Meranda P. (1997) 56 Cal.App.4th 1143, 1150-1152.)
In re Frank R. (2011) 192 Cal.App.4th 532 and In re Gladys L. (2006) 141 Cal.App.4th 845, which Mother also refers to, are similarly inapposite. In In re Frank R., the juvenile court sustained a dependency petition as to the children's mother, but found allegations against the father untrue. (In re Frank R., supra, at p. 535.) "Accordingly, father was nonoffending." (Ibid.) More importantly, the juvenile court never made "the requisite detriment finding by clear and convincing evidence as to father." (Id. at p. 539.) Therefore, "due process prohibited the termination of father's parental rights." (Ibid.) In In re Gladys L., the court held that due process prohibited the termination of the father's parental right because the county agency "never alleged that [the child's father] was unfit and the trial court never made that finding." (In re Gladys L., supra, at p. 848.)
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Although P.C. involved an offending parent, it is also distinguishable. In that case, the "only reason" the social services agency did not return the children to the mother was the mother's lack of appropriate housing. (P.C., supra, 165 Cal.App.4th at p. 105.) Significantly, the agency in that case "failed to do its part in helping mother find housing" that was suitable to the agency. (Id. at p. 106.) Indeed, the social worker actually hindered the mother's efforts by failing to timely obtain the mother's signature on a "referral that might have moved mother higher on the low-income housing list . . . ." (Ibid.) There was thus insufficient evidence to support the finding that the agency "had provided or offered all reasonable services" to the mother. (Ibid.)
Here, the reasons for not returning I.G. to Mother are varied and more complex. Although Mother completed programs required by the case plan, she did so without benefiting from them. According to the social worker, Mother was "attentive and present but had difficulty grasping the concepts and could not retain the information and was distractive to the other students." As one social worker testified, the case plan is "more than just a checklist." Merely completing the programs, she explained, is not enough; the parent must actually benefit from them.
Mother's inability to benefit from the programs was reportedly due to her "cognitive impairments and mental health concerns." CFS sought to address these concerns by providing Mother with psychotherapy services. According to the social worker at the section 366.26 hearing, these issues were not resolved. As a result, the social worker testified I.G. would be at risk if returned to Mother's care. In addition, Mother had difficulty obtaining and maintaining a stable residence. In contrast to P.C., where the agency failed to help the parent with finding housing, the social worker in this case (according to her report) "attempted to assist [M]other each time she was terminated from a sober living home."
For all these reasons, P.C. is distinguishable. To the extent the court's detriment findings are reviewable in this appeal, we find no error or violation of due process.
Alleged Father's appeal was based on his joinder in and adoption of Mother's arguments. He asserts: "If this court reverses the order terminating [M]other's parental rights, it must also reinstate [alleged] [F]ather's parental rights despite the absence of independent error pertaining to him." Because we reject Mother's arguments and affirm the orders as to her, we also reject alleged Father's argument.
IV. DISPOSITION
The orders appealed from are affirmed.
NOT TO BE PUBLISHED IN OFFICIAL REPORTS
King
J.
We concur:
Ramirez
P.J.
Miller
J.