In re R.C. CA4/2
E.S. (Mother) is the mother of six children, who now range between the ages of four and 12 years old. The children were detained pursuant to Welfare and Institutions Code section 300, based on allegations of child abuse and torture, as well as the parents’ extensive substance abuse problems. Given the severe nature of the physical abuse, services were denied to Mother, and visitation was deemed detrimental to the children. The matter progressed to a section 366.26 hearing where a permanent plan was selected and implemented. Mother subsequently filed a section 388 petition seeking reinstatement of visitation. The juvenile court summarily denied the petition without a hearing. Mother challenges the juvenile court’s denial of her section 388 petition, arguing the court abused its discretion in denying her petition without an evidentiary hearing because, by the time of the petition, prima facie evidence showed her circumstances had changed and a change order was in the children
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