California Supreme Court Watch

#25-131 In re Z.G., S289430. (E083710; nonpublished opinion; San Bernardino County Superior Court; J286808.) Petition for review after the Court of Appeal affirmed orders in a juvenile dependency proceeding. The court limited review to the following issue: 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?

Petition for review granted; issues limited: 5/14/2025

Case fully briefed: 9/23/2025

Case consolidated with: In re A.G., S289441: 11/25/2025

Cause argued and submitted: 2/04/2026

Opinion filed: judgment reversed: 4/27/2026

See the Court of Appeal Opinion.

See the Petition for Review.

See the Oral Argument.

See the California Supreme Court Opinion.  (In re Z.G. (2026) 19 Cal.5th 373.)

“We hold that a juvenile court may not terminate parental rights merely by finding a likelihood of adoption. 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. We reverse and remand.”

Justice Liu authored the opinion of the Court, in which Chief Justice Guerrero and Justices Corrigan, Kruger, Groban, Evans, and Baltodano* concurred.