In re M.G. CA3

── In re M.G. CA3 ── Court: California Court of Appeal Date: May 08, 2026 Category: General Filed 5/8/26 In re M.G. CA3 NOT TO BE PUBLISHED California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published,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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115. IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA THIRD APPELLATE DISTRICT (Tehama) In re M.G., a Person Coming Under the Juvenile Court C105014 Law. (Super. Ct. No. 25JU-000040) TEHAMA COUNTY DEPARTMENT OF SOCIAL SERVICES, Plaintiff and Respondent, v. B.T., Defendant and Appellant. B.T., the mother of minor M.G. (mother), appeals from the juvenile court’s orders denying her petition under Welfare and Institutions Code section 388 and terminating her parental rights under section 366.26.1 She maintains that she showed a change of circumstance sufficient to modify the court’s prior order bypassing her for reunification services. She also contends that the parental-benefit exception to adoption applied. We see no error in the juvenile court’s orders and therefore affirm. 1 Undesignated statutory references are to the Welfare and Institutions Code. 1  BACKGROUND I. M.G. was born to mother and G.R. (father) in April 2025. Mother has four older children (M.G.’s half-siblings) who were removed from her care in prior dependency proceedings due to unresolved substance abuse issues and neglect. She also has numerous prior convictions for drug-related offenses. Mother began drinking at age seven, started using marijuana by age nine, and was addicted to methamphetamine by age 11. At the time of the present dependency proceedings, mother was 34 years old and had struggled for over two decades battling addiction. Three days after M.G.’s birth, the Tehama County Department of Social Services (Department) filed a dependency petition alleging a failure to protect (§ 300, subd. (b)(1)) and abuse of a sibling (§ 300, subd. (j)). The petition asserted that mother had untreated substance abuse issues that hindered her ability to provide safe and adequate care for M.G. Mother received minimal prenatal care during her high-risk pregnancy and exposed M.G. to methamphetamine and THC in utero, although M.G. tested negative for substances at birth. The petition further alleged that mother’s untreated substance abuse issues had led to the removal of M.G.’s half-siblings from mother’s care. The Department’s detention report described mother’s long history of significant substance abuse. She tested positive for methamphetamine in five prior dependency cases with the Department. Her reunification services for M.G.’s half-siblings in those cases were terminated, and termination of her parental rights for those children was pending. Mother did not participate in the substance abuse or housing services the social worker offered while pregnant with M.G., and mother tested positive for THC when M.G. was born. The Department was concerned that mother would continue to abuse substances, including methamphetamine, placing M.G. at risk of being exposed to poor living conditions, lack of supervision, and threat of physical harm or neglect as her half- siblings had been. 2  The juvenile court detained M.G. in foster care and ordered supervised visits for mother five times per week for a total of five hours. The Department’s May 2025 jurisdictional report recommended that the juvenile court sustain the petition, d