In re Jason C.
Michelle C. appeals juvenile court orders summarily denying her petition for modification under Welfare and Institutions Code section 388[1] and terminating her parental rights to her minor sons, Jason C., Brandon C. and Christopher C. (collectively, the minors) under section 366.26. Michelle contends she was entitled to a hearing on her section 388 petition because she made a prima facie showing her circumstances had changed and the proposed modification—an order for additional reunification services—was in the minors' best interests. She also challenges the sufficiency of the evidence to support the court's finding the beneficial parent-child relationship exception to adoption did not apply to preclude terminating her parental rights. We affirm the orders.
FACTUAL AND PROCEDURAL BACKGROUND
In May 2011, Michelle was arrested as she attempted to enter the United States from Mexico with a substantial amount of methamphetamine and heroin in her car. The drugs were hidden under the backseat where six-year-old Jason and three-year-old Brandon were sitting. Michelle, who was eight months pregnant with Christopher, admitted she knew the drugs were in her car. She said Julio C.,[2] who was her husband and the minors' father, had made arrangements for her to smuggle the drugs from Mexico to a location in Downey, California. Michelle admitted she used Jason and Brandon to distract border patrol agents in order to avoid getting stopped.
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