Adopted Child's Interaction With Natural Parent Case Law In California

In re Autumn H. (1994) court noted that "interaction between natural parent and child will always confer some incidental benefit to the child." (Autumn H., supra, 27 Cal. App. 4th at p. 575.) The court decided the exception created by section 366.26, subdivision (c)(1)(A) applies only when the relationship with a natural parent "promotes the well-being of the child to such a degree as to outweigh the well-being the child would gain in a permanent home with new, adoptive parents." (Autumn H., supra, 27 Cal. App. 4th at p. 575.) The In re Beatrice M. (1994) court agreed with that analysis, and held that parents' "frequent and loving contact" with their children was not enough to establish the necessary benefit from continuing the relationship, when the parents "had not occupied a parental role in relation to them at any time during their lives." (Beatrice M., supra, 29 Cal. App. 4th at pp. 1418-1419.)