In re Tabatha G

In In re Tabatha G.(1996) 45 Cal. App. 4th 1159, the parent opposed termination of parental rights on the ground of the best interests of the minor based on the minor's relationship with a grandmother. The Tabatha court did not address the parent's standing to make this assertion but rather held that a minor-grandmother relationship was not a basis to deny termination of parental rights; that relationship is not one of the four exceptions listed in section 366.26, subdivision (c)(1)(A)-(D). (Tabatha, at p. 1164.) The Tabatha court stated: "In order for the court to select and implement adoption as the permanent plan, it must find, by clear and convincing evidence, the minor will likely be adopted if parental rights are terminated. ( 366.26, subd. (c)(1).) The parent then has the burden to show termination would be detrimental to the minor under one of four specified exceptions. ( 366.26, subd. (c)(1)(A), (D).)" (Ibid.)