The issue to be briefed and argued is limited to the following: Can parental rights properly be terminated pursuant to Welfare and Institutions Code section 366.26, subdivision (c)(1) when a parent did not receive reunification services and was not bypassed for such services?

On November 25, 2025, the court ordered this case consolidated for argument and decision with In re A.G., S289441/E084563.

Held: 

“[A] juvenile court may not terminate parental rights merely by finding a likelihood of adoption. [Welf. & Inst. Code,  § 366.26, subd. (c)(1).] Further, we conclude that the trial counsel here provided ineffective assistance of counsel by not asserting the mother’s statutory right to services as to one of her children and by failing to challenge the termination of services and setting of the permanency planning hearing.”

This case was decided on April 27, 2026. Justice Liu authored the unanimous opinion.