In re L.M. CA4/2

── In re L.M. CA4/2 ── Court: California Court of Appeal Date: May 07, 2026 Category: General Filed 5/7/26 In re L.M. CA4/2 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115. IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA FOURTH APPELLATE DISTRICT DIVISION TWO In re L.M., a Person Coming Under the Juvenile Court Law. E087246 RIVERSIDE COUNTY DEPARTMENT OF PUBLIC SOCIAL SERVICES, (Super.Ct.No. DPRI2200099) Plaintiff and Appellant, OPINION v. J.M. et al., Defendants and Respondents. APPEAL from the Superior Court of Riverside County. Walter H. Kubelun, Judge. Affirmed. Sarah Vaona, under appointment by the Court of Appeal, for Defendant and Appellant, J.M. William Hook, under appointment by the Court of Appeal, for Defendant and Appellant, A.M. 1  Minh C. Tran, County Counsel, Jamila T. Purnell and Julie Jarvi, Deputy County Counsel, for Plaintiff and Respondent. At a Welfare and Institutions Code section 366.26 hearing,1 the juvenile court terminated A.M.’s (mother) and J.M.’s (father, collectively parents) parental rights to L.M. (minor, born June 2019). On appeal, mother contends the court erred in declining to apply the beneficial parental relationship exception to termination of parental rights. Father joins mother’s arguments. Father filed a motion for leave to file a supplemental brief and substitute counsel. We denied father’s request, but we agreed to address father’s claims to the extent that he was contending that appellate counsel had been prejudicially ineffective in declining to raise them. Father maintains the court wrongfully terminated his reunification services. Father contends he was denied structural due process when he allegedly received no notice of the hearing on April 21, 2025, only one day’s notice of the hearing on June 6, 2025, and was denied “every procedural right available to him” at the hearing on October 27, 2025. Father asserts the court’s reduction in his visitation with minor also violated his due process rights. Additionally, father argues the maternal grandfather now recants an allegation he allegedly made that he had personally observed father assault mother in January 2023. Father argues the social worker’s pattern of misconduct denied him a fair proceeding. Finally, father contends the beneficial relationship exception applied to him. We affirm. 1 All further statutory references are to the Welfare and Institutions Code. 2  I. FACTUAL AND PROCEDURAL HISTORY2 On September 13, 2022, personnel from plaintiff and respondent the Riverside Department of Public Social Services (the department) received an immediate response referral alleging physical and emotional abuse. Mother had gone to work on September 8, 2022, where a coworker became worried after observing extensive bruising on mother’s face; the coworker shared photographs she took of mother’s face with the maternal aunt; the maternal aunt contacted the maternal grandmother; both called law enforcement. (A.M. v. Superior Court (Sep. 13, 2024, E084059) [nonpub. opn.] (A.M.).) Both parents were arrested. Officers released minor, who was asleep, to the maternal grandmother. When minor awoke, she screamed that her foot hurt, and that she could no