In re Cindy B

In In re Cindy B. (1987) 192 Cal. App. 3d 771, the juvenile court retroactively applied a newly amended version of former subdivision (a)(2) of Civil Code section 232 to allow termination of parental rights in that case. Section 232 of the Civil Code was the predecessor statute of section 366.26. On appeal, this court reversed, finding an absence of legislative intent to make the new law retroactive and no express declaration of retroactivity. (Cindy B., supra, 192 Cal. App. 3d at pp. 779-782, 787.)