In re M.G.
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Now four-year-old M.G. is fed through a G-tube due to his diagnoses of esophageal reflux, generalized intestinal dysmotility, and laryngomalacia. He is also eligible for Regional Center Services due to a developmental disability. Both parents are Regional Center consumers due to their developmental disabilities and are former foster children. During a medical appointment, the parents did not know M.G.’s feeding schedule and told the treating physician they were aggressive and hit each other. M.G. was temporarily placed in a medical foster home. DCFS filed a petition. The court found that the parents have violent altercations and mental and emotional problems and developmental delays rendering them incapable of caring for M.G., ordered M.G. removed from the custody of his parents, and ordered reunification services and monitored visitation for both parents. Ultimately, the court terminated their parental rights.
The court of appeal reversed. The juvenile court did not conduct a correct beneficial parent-child relationship analysis as set out by the California Supreme Court in “Caden C.” (2021) and instead considered factors Caden C. deems improper. Substantial evidence does not support the finding of “no bond.” The focus is not on whether M.G.’s parents can assume their parental roles but on whether M.G. will be harmed by the termination of the relationship.
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