In re Urayna L

In In re Urayna L. (1999) 75 Cal.App.4th 883, a mother argued that an assessment report prepared by the Department failed to provide any evidence about the relationship between the child and her grandmother, as required by section 366.22, subdivision (b). Accordingly, the mother argued "the trial court failed to exercise its discretion to order that the missing, and legislatively mandated, information, be provided, and that therefore it was improper for the trial court to proceed to terminate mother's parental rights in the absence of this information." ( Id. at p. 886.) Because the Department must establish the child's adoptability, the mother argued the Department's failure to adequately assess the relationship between the child and her grandmother constituted a failure on its part to satisfy its burden of proof. (Ibid.) The appellate court rejected this argument, holding the mother waived the issue of the adequacy of the report by her failure to raise it in the trial court. (Ibid.)