FIRST DISTRICT APPELLATE PROJECT

[Published Decision __ Cal.5th___] The Supreme Court held that a parent is not required to show progress in addressing issues such as drug abuse that led to the dependency in order to establish the beneficial parent-child relationship exception of WIC section 366.26, subd. (c)(1)(B)(i). With respect to the standard of review, the Court held that the first two prongs of the exceptions are reviewed for substantial evidence. The third prong, whether termination would be detrimental to the child due to the parent-child relationship, is reviewed under a hybrid standard. The factual findings as to detriment are reviewed for substantial evidence but the ultimate decision, whether the harm of losing the relationship outweighs the benefits of adoption, is reviewed under the abuse of discretion standard.