At the permanency planning hearing under Welfare and Institutions Code section 366.26, appellant mother asserted the “regular visitation and contact” exception to parental termination and demanded a contested hearing. The trial court required she present an offer of proof, found the offer of proof insufficient and terminated parental rights without a contested section 366.26 hearing. Appellant asserted it was error to require an offer of proof before granting a full hearing. The Court of Appeal affirmed the trial court procedure and order terminating parental rights, both distinguishing and disagreeing with contrary holdings in two Third District cases: In re James Q. (2000) 81 Cal.App.4th 225 and In re Kelly D. (2000) 82 Cal.App.4th 433.