beneficial parent-child relationship exception in California

2025(See In re C.F. (2011) 193 Cal.App.4th 549, 554 (C.F.) [visitation consistent near the section 366.26 hearing, but sporadic overall, is insufficient to meet the first prong of the beneficial parent-child relationship exception]; see also In re J.C. (2014) 226 Cal.App.4th 503, 531 [regular visitation prong not present when there were significant lapses in visitation]; In re I.R. (2014) 226 Cal.App.4th 201, 212 [significant lapses in visitation fatally undermines any attempt to finding beneficial parental relationship exception].) Parental Role/Attachment Even if there had been sufficient visita

2025To satisfy the second prong of the beneficial parent-child relationship exception, the “parent must show he or she occupies a parental 22 role in the child’s life, resulting in a significant, positive, emotional attachment between child and parent.” (C.F., supra, 193 Cal.App.4th at p. 555 .) “ ‘The factors to be considered when looking for whether a relationship is important and beneficial are: (1) the age of the child, (2) the portion of the child’s life spent in the parent’s custody, (3) the positive or negative effect of interaction between the parent and the child, and (4) the child’s part

2024(Autumn H., supra, 27 Cal.App.4th at p. 574 ; In re Lorenzo C. (1997) 54 Cal.App.4th 1330, 1345 .) There was no evidence at the section 366.26 hearing that severing the mother’s parental bond would cause detriment to either child, or that there were exceptional circumstances justifying the beneficial parent-child relationship exception to adoption as the preferred permanent plan.

2023(Autumn H., supra, 27 Cal.App.4th at p. 574 ; In re Lorenzo C. (1997) 54 Cal.App.4th 1330, 1345 .) There was no evidence at the section 366.26 hearing that severing the mother’s parental bond would cause detriment to either child, or that there were exceptional circumstances justifying the beneficial parent-child relationship exception to adoption as the preferred permanent plan.

2021(In re Caden C. (2019) 34 Cal.App.5th 87 , review granted July 24, 2019, S255839.) Even if we had solely applied the substantial evidence standard of review, we would still conclude the juvenile court did not err in declining to apply the beneficial parent-child relationship exception in the circumstances of this case. 11 “ ‘[F]or the [beneficial parent-child relationship] exception to apply, the emotional attachment between the child and parent must be that of parent and child rather than one of being a friendly visitor or friendly nonparent relative. . . .’ ” (In re Jason J. (2009) 175 Cal.A

2016If severing the natural parent/child relationship would deprive the child of a substantial, positive emotional attachment such that the child would be greatly harmed, the preference for adoption is overcome and the natural parent's rights are not terminated." (In re Autumn H., supra, 27 Cal.App.4th at p. 575 ; accord, In re Jason J. (2009) 175 Cal.App.4th 922, 936 .) To meet the burden of establishing the applicability of the beneficial parent-child relationship exception, a parent must show more than frequent and loving contact, an emotional bond with the child, or pleasant visits.

2021(In re Bailey J. (2010) 189 Cal.App.4th 1308 , 14 1314.) One exception is the beneficial parent-child relationship exception. (§ 366.26, subd. (c)(1)(B)(i).) “‘To trigger the application of the parental relationship exception, the parent must show the parent-child relationship is sufficiently strong that the child would suffer detriment from its termination.’ [Citation.] A beneficial relationship ‘is one that “promotes the well-being of the child to such a degree as to outweigh the well-being the child would gain in a permanent home with new, adoptive parents.” [Citation.] The existence of thi

2020(In re Bailey J. (2010) 189 Cal.App.4th 1308, 1314 .) One exception is the beneficial parent-child relationship exception. (§ 366.26, subd. (c)(1)(B)(i).) “‘To trigger the application of the parental relationship exception, the parent must show the parent-child relationship is sufficiently strong that the child would suffer detriment from its termination.’ [Citation.] A beneficial relationship ‘is one that “promotes the well-being of the child to such a degree as to outweigh the well-being the child would gain in a permanent home with new, adoptive parents.” [Citation.] The existence of this r

2026(Id. at pp. 632-633.) Third, “terminating that [parental] attachment would be detrimental to the child even when balanced against the countervailing benefit of a new, adoptive home.” (Id. at p. 636.) “Because a section 366.26 hearing occurs only after the court has repeatedly found the parent unable to meet the child’s needs, it is only in an extraordinary case that preservation of the parent’s rights will prevail over the Legislature’s preference for adoptive placement.” (In re Jasmine D. (2000) 78 Cal.App.4th 1339, 1350 , disapproved on another ground in Caden C., at p. 636, fn. 5.) We emplo

2024(Id. at pp. 632-633.) Third, “terminating that [parental] attachment would be detrimental to the child even when balanced against the countervailing benefit 23 of a new, adoptive home.” (Id. at p. 636.) “Because a section 366.26 hearing occurs only after the court has repeatedly found the parent unable to meet the child’s needs, it is only in an extraordinary case that preservation of the parent’s rights will prevail over the Legislature’s preference for adoptive placement.” (In re Jasmine D. (2000) 78 Cal.App.4th 1339, 1350 , disapproved on another ground in Caden C., at p. 636, fn. 5.) We em

2023We acknowledge that E.M. and Mother sometimes had positive interactions and visits, but this evidence falls short, particularly when considered together with the substantial evidence discussed above, of establishing the significant, positive, and emotional attachment required for the beneficial parent-child relationship exception to apply.10 (See, e.g., In re Dakota H. (2005) 132 Cal.App.4th 212, 229 [a parent must demonstrate something “more than frequent and loving contact, an emotional bond with the child, or pleasant visits”]; In re Angel B. (2002) 97 Cal.App.4th 454, 468 [“the emotional a

2022Legal Principles At a section 366.26 hearing, when the juvenile court finds by clear and convincing evidence the child is adoptable, it is generally required to terminate parental rights and order the child be placed for adoption unless a statutory exception applies. (§ 366.26, subd. (c)(1).) One of the statutory exceptions is the beneficial parent-child relationship exception, which applies when “[t]he court finds a compelling reason for determining that termination would be detrimental to the child” where “[t]he parents have maintained regular visitation and contact with the child and the ch

2024(In re Derek W. (1999) 73 Cal.App.4th 823, 826 .) At the selection and implementation hearing, the court must terminate parental rights if the child is likely to be adopted within a reasonable time unless one of the statutory exceptions applies. (§ 366.26, subd. (c)(1)(B)(i)-(vi).) One such exception is the beneficial parent-child relationship exception, which applies when “[t]he court finds a compelling reason for determining that termination would be detrimental to the child” because “[t]he parents have maintained regular visitation and contact with the child and the child would benefit from

2021First, the parent must show that he or she has “maintained regular visitation and contact with the 11 minor.’ ” (In re Derek W. (1999) 73 Cal.App.4th 823, 826 .) Second, the parent must show that his or her relationship with the child “promotes the well-being of the child to such a degree as to outweigh the well-being the child would gain in a permanent home with new, adoptive parents.” (In re Autumn H. (1994) 27 Cal.App.4th 567, 575 (Autumn H.).) “When applying the beneficial parent-child relationship exception, the court balances the strength and quality of the parent-child relationship in a

2021DISCUSSION At a section 366.26 hearing, when the juvenile court finds by clear and convincing evidence the child is adoptable, it is generally required to terminate parental rights and order the child be placed for adoption unless a statutory exception applies. (§ 366.26, subd. (c)(1).) One of the statutory exceptions is the beneficial parent-child relationship exception, which applies when “[t]he court finds a compelling reason for determining that termination would be detrimental to the child” where “[t]he parents have maintained regular visitation and contact with the child and the child wo

2016(In re Aaliyah R. (2006) 136 Cal.App.4th 437, 449 .) There appears to be little dispute between the parties as to whether mother satisfied her burden to establish the first prong of the beneficial parent-child relationship exception—namely, that she “maintained regular visitation and contact” with her daughter. (§ 366.26, subd.(c)(1)(B)(i).) Nevertheless, we do not reach that issue because the trial court did not err in concluding mother failed to meet her burden, under the second prong, to show that J.F. would benefit from continuing her relationship with mother. (§ 366.26, subd.(c)(1)(B)(i).

2023We acknowledge that E.M. and Mother sometimes had positive interactions and visits, but this evidence falls short, particularly when considered together with the substantial evidence discussed above, of establishing the significant, positive, and emotional attachment required for the beneficial parent-child relationship exception to apply.10 (See, e.g., In re Dakota H. (2005) 132 Cal.App.4th 212, 229 [a parent must demonstrate something “more than frequent and loving contact, an emotional bond with the child, or pleasant visits”]; In re Angel B. (2002) 97 Cal.App.4th 454, 468 [“the emotional a

2022(In re Dakota H. (2005) 132 Cal.App.4th 212, 230 (Dakota H.).) Here, the court found that Mother had not consistently been in A.W.’s life, thereby implicitly finding she had not satisfied the first prong of the beneficial parent-child relationship exception.

2022(In re Autumn H. (1994) 27 Cal.App.4th 567, 574 (Autumn H.); see In re Celine R. (2003) 31 Cal.4th 45, 53 [“The statutory exceptions merely permit the court, in exceptional circumstances [citation], to choose an option other than the norm, which remains adoption.”].) One such circumstance is the beneficial parent-child relationship exception set forth in section 366.26, subdivision (c)(1)(B)(i).

2022(In re Celine R. (2003) 31 Cal.4th 45, 53 .) Unlike the beneficial parent-child relationship exception, the juvenile court is permitted to consider the prospective adoptive parent’s intent to maintain contact between the siblings.

2013(In re Beatrice M. (1994) 29 Cal.App.4th 1411, 1419 [Legislature has decreed guardianship is not in best interests of children who cannot be returned to their parents; only adoption affords the most permanent and secure alternative]; In re Ronell A. (1996) 44 Cal.App.4th 1352 , 1368- 1369 [parents' preference to preserve family unit does not override best interests of minors in stability and security of adoptive home].) There was substantial evidence to support the court's finding that the beneficial parent-child relationship exception did not apply to preclude terminating parental rights.

2013(In re Beatrice M. (1994) 29 Cal.App.4th 1411, 1419 [Legislature has decreed guardianship is not in best interests of children who cannot be returned to their parents; only adoption affords the most permanent and secure alternative]; In re Ronell A. (1996) 44 Cal.App.4th 1352, 1368-1369 [parents' preference to preserve family unit does not override best interests of minors in stability and security of adoptive home].) Substantial evidence supports the court's finding the beneficial parent-child relationship exception did not apply to preclude terminating parental rights. 16 DISPOSITION The ord

2026(See In re G.B. (2014) 227 Cal.App.4th 1147, 1166 [“ ‘ “it is only in an extraordinary case that preservation of the parent’s rights will prevail over the Legislature’s preference for adoptive placement” ’ ”].) Rather, the court reasonably concluded maintaining A.L.’s relationship with Mother did not outweigh “ ‘the security and the sense of belonging a new family would confer.’ ” (Caden C., supra, 11 Cal.5th at p. 633.) There was thus no abuse of discretion in the court declining to apply the beneficial parent-child relationship exception in this matter.

2024(In re G.B. (2014) 227 Cal.App.4th 1147, 1166 [“ ‘ “it is only in an extraordinary case that preservation of the parent’s rights will prevail over the Legislature’s preference for adoptive placement” ’ ”].) Based on the present record, we cannot find that the court erred in declining to apply the beneficial parent-child relationship exception.

2023Finally, Cristela R. suggests the juvenile court erred in relying “on a promise” from Edgar Sr. (who was not present at the section 366.26 hearing) “there will be a future relationship between the child and the parent in analyzing the beneficial parent-child relationship exception.” As stated, Caden C. requires the court to “assume that terminating parental rights terminates the relationship.” (Caden C., supra, 11 Cal.5th at p. 633.) Thus, in determining whether to terminate parental rights, the court may not consider “the prospective adoptive parents’ willingness to allow the children to have

2022(People v. Patterson (2017) 2 Cal.5th 885, 894 .) Father is also correct that it is an error of law for a juvenile court—when considering whether to apply the beneficial parent-child relationship exception—to give any weight to “an unenforceable promise of future visitation by the child’s prospective adoptive parents.” (In re S.B. (2008) 164 Cal.App.4th 289 , 300 (S.B.); In re C.B. (2010) 190 Cal.App.4th 102, 127-129 (C.B.).) But father is incorrect that we should presume—by virtue of the fact that Valerie’s attorney mentioned this impermissible factor—that the juvenile court factored it into

2024(In re J.S. (2017) 10 Cal.App.5th 1071, 1081 .) This includes, “a meaningful opportunity to be heard, present evidence, and confront witnesses.” (In re Grace P. (2017) 8 Cal.App.5th 605, 612 .) Just what amount of process is due “ ‘is a flexible concept which depends upon the circumstances and a balancing of various factors.’ ” (In re J.S., at p. 1081.) At a section 366.26 hearing, the juvenile court must determine by clear and convincing evidence whether the child is adoptable; and if a child is adoptable, the juvenile court must then terminate parental rights and order the child be placed fo

2021It is undisputed that Mother maintained regular contact and visitation with M.G. and therefore met the first prong of the beneficial parent-child relationship exception. (§ 366.26, subd. (c)(1)(B)(i) [“parents have maintained regular visitation and contact with the child”].) Thus, the issue before us is whether Mother met her burden with regard to the second prong—whether she had a beneficial parental relationship with M.G. that “is sufficiently strong that the child would suffer detriment from its termination.” (In re Grace P. (2017) 8 Cal.App.5th 605, 613 .) The record shows that Mother had

2021(In re Lorenzo C. (1997) 54 Cal.App.4th 1330, 1343 .) “Because a section 366.26 hearing occurs only after the court has repeatedly found the parent unable to meet the child’s needs, it is only in an extraordinary case that preservation of the parent’s rights will prevail over the Legislature’s preference for adoptive placement.” (In re Jasmine D. (2000) 78 Cal.App.4th 1339, 1350 .) One of the exceptions to the preference for adoption is the beneficial parent-child relationship exception, which exists where a parent has “maintained regular visitation and contact with the child and the child wou

2015(In re Anthony B., supra, 239 Cal.App.4th at p. 395 .) Mother contends the juvenile court erred when it found the beneficial parent- child relationship exception did not apply.4 In particular, pointing to Chiler's testimony and reports that Mother exhibited a "parental role" with M.E., she maintains substantial evidence does not support the court's finding that no parent-child relationship existed between her and M.E.

2026(In re J.C. (2014) 226 Cal.App.4th 503, 529 .) On appeal, we apply a hybrid standard in reviewing a juvenile court’s determination whether the beneficial parent-child relationship exception applies.

2025(See In re C.F. (2011) 193 Cal.App.4th 549, 554 (C.F.) [visitation consistent near the section 366.26 hearing, but sporadic overall, is insufficient to meet the first prong of the beneficial parent-child relationship exception]; see also In re J.C. (2014) 226 Cal.App.4th 503, 531 [regular visitation prong not present when there were significant lapses in visitation]; In re I.R. (2014) 226 Cal.App.4th 201, 212 [significant lapses in visitation fatally undermines any attempt to finding beneficial parental relationship exception].) Parental Role/Attachment Even if there had been sufficient visita

2025To satisfy the second prong of the beneficial parent-child relationship exception, the “parent must show he or she occupies a parental 22 role in the child’s life, resulting in a significant, positive, emotional attachment between child and parent.” (C.F., supra, 193 Cal.App.4th at p. 555 .) “ ‘The factors to be considered when looking for whether a relationship is important and beneficial are: (1) the age of the child, (2) the portion of the child’s life spent in the parent’s custody, (3) the positive or negative effect of interaction between the parent and the child, and (4) the child’s part

2023(In re Bailey J. (2010) 189 Cal.App.4th 1308, 1314 .) One exception is the beneficial parent-child relationship exception. (§ 366.26, subd. (c)(1)(B)(i).) In Caden C., our Supreme Court examined this exception and held that a drug-addicted parent’s failure to succeed in drug rehabilitation programs and continuing struggles with addiction did not, on its own, disqualify the parent from being accorded the beneficial parent-child relationship exception.

2026Pertinent Law Once a juvenile court has terminated reunification services, the court “shall terminate parental rights” if it finds, ‘“by clear and convincing evidence[,] that it is likely that the [child] will be adopted’” within a reasonable time. (§ 366.26, subd. (c)(1); Cynthia D. v. Superior Court (1993) 5 Cal.4th 242, 249 .) Thus, a 8 juvenile court must terminate parental rights and order adoption unless the parent opposing termination proves that one of six statutory exceptions applies. (§ 366.26, subds. (c)(1) & (c)(1)(B); In re I.W. (2009) 180 Cal.App.4th 1517, 1527 , overruled in par

2025A court abuses its discretion only when ‘ “ ‘the trial court has exceeded the limits of legal discretion by making an arbitrary, capricious, or patently absurd determination.’ ” ’ ” (Id. at p. 641.) The standard of review for a court’s determination that a parent did not meet his or her burden to prove the beneficial parent-child relationship exception before terminating parental rights is “whether the evidence compels a finding in favor of the [parent] as a matter of law.” (In re I.W. (2009) 180 Cal.App.4th 1517 , 1528, disapproved on other grounds by Conservatorship of O.B. (2020) 9 Cal.5th

2021(Stephanie M., supra, 7 Cal.4th at p. 317 ; G.B., supra, 227 Cal.App.4th at p. 1157 ; A.A., supra, 203 Cal.App.4th at p. 612 ; Casey D., supra, 70 Cal.App.4th at p. 47 ; Jasmon O., supra, 8 Cal.4th at pp. 415-416; Y.M., supra, 207 Cal.App.4th at p. 920 .) II Beneficial Parent-Child Relationship Exception Mother contends the juvenile court erred when it terminated her parental rights, asserting she established the beneficial parent-child relationship exception to adoption applied. (§ 366.26, subd. (c)(1)(B)(i).) We disagree with this assertion as well.

2016Because we reject Mother’s contention the beneficial parent-child relationship exception applied to preclude adoption as to I.E. as well as his siblings, we need not address this contention. 15 the child would benefit from continuing the relationship.” (Id., subd. (c)(1)(B)(i); see In re Casey D. (1999) 70 Cal.App.4th 38, 50 .) Here, the juvenile court found, and the record reflects, Mother maintained regular visitation with the children.

2021(In re Michael G. (2012) 203 Cal.App.4th 580, 589 .) One of these statutory exceptions is the beneficial parent-child relationship exception to adoption, which applies when it would be detrimental to the child to terminate parental rights in that “[t]he parents have maintained regular visitation and contact with the child and the child would benefit from continuing the relationship.” (§ 366.26, subd. (c)(1)(B)(i).)5 Mother had the 5 “Regular visitation exists where the parents visit consistently and to the extent permitted by court orders.” (In re I.R. (2014) 226 Cal.App.4th 201, 212 .) “Spora

2014(Michael G., supra, 203 Cal.App.4th at p. 589 ; In re Erik P. (2002) 104 Cal.App.4th 395, 401 .) The beneficial parent-child relationship exception found in section 366.26(c)(1)(B)(i) provides an exception to the adoption preference if the juvenile court finds a "compelling reason" for determining that termination of parental rights would be "detrimental" to the child because "[t]he parents have maintained regular visitation and contact with the child and the child would benefit from continuing the relationship." (§ 366.26(c)(1)(B)(i), italics added.) This court has interpreted the statutory p

2025(See In re C.F. (2011) 193 Cal.App.4th 549, 554 (C.F.) [visitation consistent near the section 366.26 hearing, but sporadic overall, is insufficient to meet the first prong of the beneficial parent-child relationship exception]; see also In re J.C. (2014) 226 Cal.App.4th 503, 531 [regular visitation prong not present when there were significant lapses in visitation]; In re I.R. (2014) 226 Cal.App.4th 201, 212 [significant lapses in visitation fatally undermines any attempt to finding beneficial parental relationship exception].) Parental Role/Attachment Even if there had been sufficient visita

2021(In re Michael G. (2012) 203 Cal.App.4th 580, 589 .) One of these statutory exceptions is the beneficial parent-child relationship exception to adoption, which applies when it would be detrimental to the child to terminate parental rights in that “[t]he parents have maintained regular visitation and contact with the child and the child would benefit from continuing the relationship.” (§ 366.26, subd. (c)(1)(B)(i).)5 Mother had the 5 “Regular visitation exists where the parents visit consistently and to the extent permitted by court orders.” (In re I.R. (2014) 226 Cal.App.4th 201, 212 .) “Spora

2024(In re Melvin A. (2000) 82 Cal.App.4th 1243, 1252 .) To establish the beneficial parent-child relationship exception, the parent must show by a preponderance of the evidence three elements: (1) regular visitation and contact, and (2) a relationship, the continuation of which would benefit the child such that (3) the termination of parental rights would be detrimental to the child.

2024(See In re Rachel M. (2003) 113 Cal.App.4th 1289, 1295 [“[t]he juvenile court does not have a sua sponte duty to determine whether an exception to adoption applies”]; see also In re Daisy D. (2006) 144 Cal.App.4th 287, 292 [same, with regard to the beneficial sibling relationship exception]; In re Melvin A., supra, 82 Cal.App.4th at p. 1252 .) Here, mother’s counsel did not argue at the section 366.26 hearing that the beneficial parent-child relationship exception to termination of parental rights applied.

2022(People v. Patterson (2017) 2 Cal.5th 885, 894 .) Father is also correct that it is an error of law for a juvenile court—when considering whether to apply the beneficial parent-child relationship exception—to give any weight to “an unenforceable promise of future visitation by the child’s prospective adoptive parents.” (In re S.B. (2008) 164 Cal.App.4th 289 , 300 (S.B.); In re C.B. (2010) 190 Cal.App.4th 102, 127-129 (C.B.).) But father is incorrect that we should presume—by virtue of the fact that Valerie’s attorney mentioned this impermissible factor—that the juvenile court factored it into

2021(See In re J.C., supra, 226 Cal.App.4th at pp. 530-531.) Mother asserts this case is like In re S.B. (2008) 164 Cal.App.4th 289 (S.B.), one of the few cases in which an appellate court has determined the juvenile court should have applied the beneficial parent-child relationship exception to preclude adoption.

2021In determining whether the relationship between parent and child is beneficial, the court looks to such factors as the age of the child, the portion of the child’s life spent in the parent’s custody, the positive or negative effect of 4 Appellate courts have adopted differing standards of review for the beneficial parent-child relationship exception: substantial evidence (see, e.g., In re G.B. (2014) 227 Cal.App.4th 1147, 1165 ); abuse of discretion (see, e.g., In re Aaliyah R. (2006) 136 Cal.App.4th 437, 449 ); and, more recently, a “hybrid” standard, which reviews the juvenile court’s factua

2021(In re Breanna S., at p. 647.) “ ‘ “The appropriate test for abuse of discretion is whether the trial court exceeded the bounds of reason.” ’ ” (In re Stephanie M. (1994) 7 Cal.4th 295 , 318–319.)3 3 Appellate courts have adopted differing standards of review for the beneficial parent-child relationship exception: substantial evidence (see, e.g., In re G.B. (2014) 227 Cal.App.4th 1147, 1165 ); abuse of discretion (see, e.g., In re Aaliyah R. (2006) 136 Cal.App.4th 437, 449 ); and, more recently, as we have applied here, a “hybrid” standard (In re Breanna S., supra, 8 Cal.App.5th at p. 647 .) T

2024(In re J.S. (2017) 10 Cal.App.5th 1071, 1081 .) This includes, “a meaningful opportunity to be heard, present evidence, and confront witnesses.” (In re Grace P. (2017) 8 Cal.App.5th 605, 612 .) Just what amount of process is due “ ‘is a flexible concept which depends upon the circumstances and a balancing of various factors.’ ” (In re J.S., at p. 1081.) At a section 366.26 hearing, the juvenile court must determine by clear and convincing evidence whether the child is adoptable; and if a child is adoptable, the juvenile court must then terminate parental rights and order the child be placed fo

2021DISCUSSION At a section 366.26 hearing, when the juvenile court finds by clear and convincing evidence the child is adoptable, it is generally required to terminate parental rights and order the child be placed for adoption unless a statutory exception applies. (§ 366.26, subd. (c)(1).) One of the statutory exceptions is the beneficial parent-child relationship exception, which applies when “[t]he court finds a compelling reason for determining that termination would be detrimental to the child” where “[t]he parents have maintained regular visitation and contact with the child and the child wo

2021DISCUSSION At a section 366.26 hearing, when the juvenile court finds by clear and convincing evidence the child is adoptable, it is generally required to terminate parental rights and order the child be placed for adoption unless a statutory exception applies. (§ 366.26, subd. (c)(1).) One of the statutory exceptions is the beneficial parent-child relationship exception, which applies when “[t]he court finds a compelling reason for determining that termination would be detrimental to the child” where “[t]he parents have maintained regular visitation and contact with the child and the child wo

2021(In re Breanna S., at p. 647.) “ ‘ “The appropriate test for abuse of discretion is whether the trial court exceeded the bounds of reason.” ’ ” (In re Stephanie M. (1994) 7 Cal.4th 295 , 318–319.)3 3 Appellate courts have adopted differing standards of review for the beneficial parent-child relationship exception: substantial evidence (see, e.g., In re G.B. (2014) 227 Cal.App.4th 1147, 1165 ); abuse of discretion (see, e.g., In re Aaliyah R. (2006) 136 Cal.App.4th 437, 449 ); and, more recently, as we have applied here, a “hybrid” standard (In re Breanna S., supra, 8 Cal.App.5th at p. 647 .) T