In re A.G. CA2/6

── In re A.G. CA2/6 ── Court: California Court of Appeal Date: May 19, 2026 Category: General Filed 5/19/26 In re A.G. CA2/6 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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 SECOND APPELLATE DISTRICT DIVISION SIX In re A.G., A Person Coming 2d Juv. No. B349620 Under the Juvenile Court Law. (Super. Ct. No. J073534) (Ventura County) VENTURA COUNTY HUMAN SERVICES AGENCY, Respondent, v. L.S.C., Appellant. L.S.C. (mother) appeals the juvenile court’s order terminating parental rights as to A.G. (Welf. & Inst. Code § 366.26.)1 Mother contends: (1) the court prejudicially erred in 1 Undesignated statutory references are to the Welfare and Institutions Code. denying her parental bond exception; and (2) Ventura County Human Services Agency (Agency) and the juvenile court failed to adequately comply with the inquiry requirements of the Indian Child Welfare Act (ICWA) and its state counterpart. We will affirm. FACTUAL AND PROCEDURAL BACKGROUND On August 13, 2024, the Agency filed a section 300 petition regarding A.G., born in August 2024. The petition alleged mother tested positive for methamphetamine and fentanyl at birth. Both mother and father had substance abuse issues that periodically interfered with their ability to provide adequate care and supervision. A.G. entered the care of resource parents within days of birth. At an uncontested jurisdiction and disposition hearing, the juvenile court sustained the petition. It offered reunification services to mother but bypassed services for father. After minor’s counsel requested a contested six-month review hearing, the parties ultimately came to an agreement. Reunification services were terminated and a section 366.26 hearing was set. If mother entered a program and did well, her counsel would file a JV-180 request. During the dependency period, mother had struggled with sobriety as she entered and exited drug treatment programs and failed or refused drug tests. At the section 366.26 hearing, mother testified she currently visited A.G. three times per week for 90 minutes. Her visitation schedule had varied throughout the case, but she had missed just one visit. At the visits, they played and shared meals, and mother bathed him. A.G. cried when mother put him in the car. Mother usually tried to comfort him by giving him a toy or bottle, or by hugging and kissing him. Mother believed 2 A.G. had a strong bond with her because of how happy he was to see her and she “could just feel it as a mom.” According to the section 366.26 report, there was “no evidence to support that [A.G.] and the parents have such a significant relationship that it would be detrimental to [A.G.] if this relationship was severed.” The report noted that although mother’s visitation had been liberalized, it “was returned back to monitored six months ago due to the mother’s lack of progress in services and failure to demonstrate that she is sober and engaged in treatment.” Regarding the parental-benefit exception, the court acknowledged mother satisfied the first prong of visitation. As to the second prong, the court could not find a positive emotional attachment. The court noted it needed to consider factors like the child’s age and the amount of time spent in mother’s care. At one point, the court addressed mother as follows: “And I think you would acknowledge that there’s still quite a bit of things that you need to work on. And so here’s an