In re N.A. CA4/2
S.G. (Mother) had unresolved mental health issues and a history of abusing drugs and neglecting her five-year-old son N.A. that led to the Riverside County Department of Public Social Services (DPSS) removing N.A. from her home. After over 18 months of reunification services, services for both Mother and Father were terminated and a Welfare and Institutions Code section 366.26 hearing was set. Mother filed a section 388 petition requesting additional reunification services and increased visits with N.A. The petition was denied without an evidentiary hearing. Mother appealed after her parental rights were terminated. On appeal, Mother contends the juvenile court erred in summarily denying her section 388 petition without a hearing because she met the requisite “probable cause” to trigger an evidentiary hearing.
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