Caden C analysis in California

2026(Caden C., supra, 11 Cal.5th at p. 636; cf. Autumn H., supra, 27 Cal.App.4th at p. 575 .) The juvenile court properly applied the third prong of the Caden C. factors and its conclusion that no evidence supported a finding that the detriment of severing M.C.’s relationship with Mother outweighed the benefits of adoption is supported by the record.

2024(Caden C., supra, 11 Cal.5th at p. 636; cf. Autumn H., supra, 27 Cal.App.4th at p. 575 .) Contrary to Mother’s 12 conclusory and unsupported assertion, there is nothing in the record showing that the court “failed to properly apply the Caden C. factors.” To the extent Mother cites evidence or inferences that would have supported a contrary finding by the court on the third prong, she misapplies the abuse of discretion standard of review.

2025No Error Father, joined by Mother, claims that the juvenile court, in finding P.S. and A.S. were adoptable and no exception applied, failed to follow the Caden C. analysis. “‘“We must indulge in every presumption to uphold a judgment, and it is [appellants’] burden on appeal to affirmatively demonstrate error—it will not be presumed.”’” (In re A.L. (2022) 73 Cal.App.5th 1131 , 1161 (A.L.).) Further, “‘[i]n the absence of evidence to the contrary, we presume that the court “knows and applies the correct statutory and case law.”’” (People v. Jones (2017) 3 Cal.5th 583, 616 , quoting People v. Th

2025Citing In re L.A.-O. (2021) 73 Cal.App.5th 197 , 210–212; In re D.M. (2021) 71 Cal.App.5th 261 , 268, and In re J.D. (2021) 70 Cal.App.5th 833 , 864, Mother asserts “[r]eversal is required in cases where a court merely summarily states, as the [juvenile] court did here, that the parent had not occupied a parental role and it cannot be determined whether the court considered proper or improper factors [under Caden C.].” We reject this proposition as it ignores our duty to “ ‘presume’ ” juvenile courts “ ‘ “know[] and appl[y] the correct statutory and case law.” ’ ”3 (In re A.L., supra, 73 Cal.A

2022(In re Breanna S. (2017) 8 Cal.App.5th 636, 646-647 , disapproved on other grounds in Caden C., supra, 11 Cal.5th at pp. 637, fn. 6, 638, fn. 7; compare In re D.M., supra, 71 Cal.App.5th at p. 271 [remand appropriate where primary source of error is in the third element of the analysis, it thus being unclear “how the [juvenile] court would have exercised its discretion” to balance the potential detriment of termination against the potential benefits of adoption without “the benefit of the Caden C. analysis”].) Therefore, in light of our ruling on the second prong, we need not address father’s

2022(In re Breanna S. (2017) 8 Cal.App.5th 636, 646-647 , disapproved on other grounds in Caden C., supra, 11 Cal.5th at pp. 637, fn. 6, 638, fn. 7; compare In re D.M., supra, 71 Cal.App.5th at p. 271 [remand appropriate where primary source of error is in the third element of the analysis, it thus being unclear “how the [juvenile] court would have exercised its discretion” to balance the potential detriment of termination against the potential benefits of adoption without “the benefit of the Caden C. analysis”].) Therefore, in light of our ruling on the second prong, we need not address father’s

2026(In re Zamer G. (2007) 153 Cal.App.4th 1253, 1271 .) In this case, the Agency reports and the exhibits admitted into evidence establish that many of the Caden C. factors—including K.M.’s age and the portion of her life spent out of Mother’s care—weigh against a finding in favor of Mother on the second element of the beneficial relationship exception.

2026(Caden C., at p. 641; In re Stephanie M. (1994) 7 Cal.4th 295 , 318–319.) Appellants do not call into question the court’s analysis as to the first prong of the three-prong Caden C. test for the beneficial parent-child relationship exception when it found Mother had maintained regular visitation and contact with M.C.

2025No Error Father, joined by Mother, claims that the juvenile court, in finding P.S. and A.S. were adoptable and no exception applied, failed to follow the Caden C. analysis. “‘“We must indulge in every presumption to uphold a judgment, and it is [appellants’] burden on appeal to affirmatively demonstrate error—it will not be presumed.”’” (In re A.L. (2022) 73 Cal.App.5th 1131 , 1161 (A.L.).) Further, “‘[i]n the absence of evidence to the contrary, we presume that the court “knows and applies the correct statutory and case law.”’” (People v. Jones (2017) 3 Cal.5th 583, 616 , quoting People v. Th

2025And the relationship may be shaped by a slew of factors, such as ‘[t]he age of the child, the portion of the child’s life spent in the parent’s custody, the “positive” or “negative” effect of interaction between parent and child, and the child’s particular needs.’ [Citation.]” (Id. at p. 632.) “[C]ourts often consider how children feel about, interact with, look to, or talk about their parents.” (Ibid.) To carry the burden on this element, a parent “must show more than frequent and loving contact or pleasant visits.” (In re C.F. (2011) 193 Cal.App.4th 549, 555 ; In re G.H. (2022) 84 Cal.App.5t

2024(In re Jonathan B. (1992) 5 Cal.App.4th 873, 875 .) The juvenile court found the mother had not satisfied parts two or three of the Caden C. test, and the section 366.26, subdivision (c)(1)(B)(i) exception therefore did not apply.

2024Mother urges this court to follow In re E.T. (2018) 31 Cal.App.5th 68, 77 , in which the appellate court wrote, “The standard is whether the children benefit from Mother’s presence in their lives, not whether they could eventually be happy without her.” For the sake of addressing Mother’s argument, we will apply the foregoing benefit standard. “ ‘We apply the substantial evidence standard of review to the factual issue of the existence of a beneficial parental relationship.” (Id. at p. 76.) M.W. was removed from Mother’s custody in December 2021 due to Mother’s boyfriend physically abusing M.W

2023DISCUSSION A. Governing Law and Standard of Review “At the section 366.26 hearing, the focus shifts away from family reunification and toward the selection and implementation of a permanent plan for the child.” (In re S.B. (2009) 46 Cal.4th 529 , 532; accord, Caden C., supra, 11 Cal.5th at p. 630.) “‘Once the court determines the child is likely to be adopted, the burden shifts to the parent to show that termination of parental rights would be detrimental to the child under one of the exceptions listed in section 366.26, subdivision (c)(1).’” (In re B.D. (2021) 66 Cal.App.5th 1218 , 1224-1225