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In re Raymond A.
The juvenile court declared two-year-old Raymond A. a dependent of the court pursuant to Welfare and Institutions Code section 300, subdivision (b)[1] and ordered reunification services for the child’s mother. Over the next 18 months, mother repeatedly used methamphetamine, was arrested on multiple occasions and failed to comply with the court’s case treatment plan. The juvenile court terminated reunification services and set a hearing on the termination of parental rights pursuant to section 366.26.
On the morning of the section 366.26 hearing, mother filed a section 388 petition arguing that the juvenile court should reinstate reunification because she had completed a drug treatment program and obtained housing. The juvenile court summarily denied the petition, terminated parental rights and selected adoption by maternal grandparents as the child’s permanent plan.
Mother appeals the juvenile court’s orders, arguing that: (1) she was entitled to a hearing on her section 388 petition; and (2) the juvenile court erred by not applying the beneficial parental relationship exception to parental termination. We affirm.

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