San Diego County Health & Human Services Agency v. Gala G.

*803Opinion

MCDONALD,J.

Gala G. (Mother) filed a petition pursuant to Welfare and Institutions Code section 3881 (hereafter the section 388 petition), alleging changed circumstances and seeking to modify the order terminating reunification services for her child Zachary G. (Zachary). The court denied a hearing on the section 388 petition and thereafter terminated Mother’s parental rights at the section 366.26 hearing (the .26 hearing). Mother contends both rulings were erroneous.

I

Factual and Procedural History

A. Mother’s History

Prior to Zachary’s birth Mother had two children, including Austin, who…