In re Z.G.

── In re Z.G. ── Court: California Supreme Court Date: April 27, 2026 Category: General IN THE SUPREME COURT OF CALIFORNIA In re Z.G. et al., Persons Coming Under the Juvenile Court Law. SAN BERNARDINO COUNTY CHILDREN AND FAMILY SERVICES, Plaintiff and Respondent, v. A.G., Defendant and Appellant. S289430 In re A.G. on Habeas Corpus. S289441 Fourth Appellate District, Division Two E083710, E084563 San Bernardino County Superior Court J286808, J289966 April 27, 2026 Justice Liu authored the opinion of the Court, in which Chief Justice Guerrero and Justices Corrigan, Kruger, Groban, Evans, and Baltodano* concurred. * Associate Justice of the Court of Appeal, Second Appellate District, Division Six, assigned by the Chief Justice pursuant to article VI, section 6 of the California Constitution.  In re Z.G.* S289430 Opinion of the Court by Liu, J. In these consolidated cases, the juvenile court terminated a mother’s parental rights as to her two children after finding they were likely to be adopted. It is undisputed that the mother received statutorily guaranteed reunification services as to one child and that she did not receive reunification services as to her other child. Her trial counsel did not assert her statutory right to such services at the disposition hearing where the juvenile court terminated services and set a permanency planning hearing. After the mother filed a notice of intent to challenge that outcome, her trial counsel did not prosecute the challenge. We hold that a juvenile court may not terminate parental rights merely by finding a likelihood of adoption. Further, we conclude that the trial counsel here provided ineffective assistance of counsel by not asserting the mother’s statutory right to services as to one of her children and by failing to challenge the termination of services and setting of the permanency planning hearing. We reverse and remand. I. This case comes to us from dependency proceedings involving two children. “Dependency proceedings span up to four stages: jurisdiction, disposition, reunification, and permanency. [Citations.] At the jurisdictional stage, the * Consolidated with In re A.G. (S289441). 1  In re Z.G. Opinion of the Court by Liu, J. juvenile court determines whether to declare a child a dependent of the court because the child is suffering, or at risk of suffering, significant harm. [Citation.] At the dispositional stage, the court decides if the child can be returned to, or must be removed from, a parent’s custody. [Citations.]” (Michael G. v. Superior Court (2023) 14 Cal.5th 609, 624, fn. omitted (Michael G.).) The final two stages, reunification and permanency, are at issue here. “During the reunification stage, qualifying parents are offered services to address the causes that led to the loss of custody.” (Michael G., supra, 14 Cal.5th at p. 624.) These reunification services “ ‘ “implement ‘the law’s strong preference for maintaining the family relationships if at all possible.’ ” ’ ” (Ibid.) “When the child is removed from the home, the court first attempts, for a specified period of time, to reunify the family.” (In re Celine R. (2003) 31 Cal.4th 45, 52 (Celine R.).) If reunification services are ineffectual, then the court moves to the next stage by “ ‘terminat[ing] reunification efforts and set[ting] the matter for a hearing pursuant to [Welfare and Institutions Code] section 366.26.’ ” (Ibid.; all undesignated statutory references are to the Welfare and Institutions Code.) At the permanency stage, the court “either terminates parental rights and places the child up for adoption or it select