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Name: In re C.F.
Case #: D058382
Court: CA Court of Appeal
District 4 DCA
Division: 1
Opinion Date: 03/16/2011

Beneficial parent-child relationship exception to adoption did not apply where mother has played no parental role in the minors’ lives. On appeal from parental rights termination, mother challenged the sufficiency of evidence to support the court’s finding that the beneficial parent-child relationship was inapplicable. The appellate court rejected the argument and affirmed. Mother’s visitation was consistent at times, but not at others. Sporadic visitation is insufficient to establish the first prong of the exception. Further, even if mother’s visitation was deemed to be regular, there was no evidence that mother played a parental role in the minors’ lives. The minors were happy to see her and had an emotional bond with her, but they looked to the relative guardians to meet their needs. In re S.B. (2008) 164 Cal.App.4th 289, does not support the proposition that a parent may establish the parent-child relationship exception by merely showing the child derives some meaasure of benefit from maintaining parental contact.