In In re Raymond E. (2002) 97 Cal.App.4th 613, the Court rejected the argument that the 2001 amendment adding subpart (E) to section 366.26, subdivision (c)(1) should be retroactively applied. The mother in Raymond E. argued the amendment is analogous to a criminal statute amended to lessen the punishment for an offense, and additionally argued the Legislature intended the amendment to apply retroactively. Raymond E. noted the general rule that statutes are presumed to operate prospectively and are applied retroactively only when the Legislature clearly expresses that intent. ( Id. at p. 616.) The court noted there is no express language in section 366.26, subdivision (c)(1)(E) mandating retroactivity (ibid.), and found nothing in the legislative materials submitted by the mother suggesting the Legislature intended the amendment to apply retroactively. ( Id. at pp. 617, 618.) Rejecting the analogy between the amendment and criminal statutes lessening punishment, Raymond E. stated: "By creating an additional exception to adoption based on substantial interference with a sibling relationship, the Legislature was not . . . necessarily conferring a new 'benefit' on parents and minors akin to a lesser punishment in the criminal context. Moreover, . . . there is no indication the Legislature determined that some orders terminating parental rights had interfered unduly with strong sibling relationships. It is just as likely the Legislature acted simply in recognition of the importance placed recently on preserving sibling relationships and sought to provide the juvenile court with the flexibility required to address that issue." ( Raymond E., supra, 97 Cal.App.4th at p. 616.) Raymond E. concluded: "The amendment to section 366.26 was not accompanied by any expression of intent or language making it retroactive. Thus, no reason exists to depart from the general presumption in the law against retroactivity." ( Raymond E., supra, 97 Cal.App.4th at p. 618.)