In Tracy J. v. Superior Court (2012) 202 Cal.App.4th 1415, the parents sought writ review of juvenile court orders terminating family reunification services and setting a section 366.26 hearing. (Tracy J., supra, 202 Cal.App.4th at p. 1419.) The mother argued that she was not offered or provided reasonable family reunification services and the juvenile court abused its discretion in not extending the reunification period. (Id. at p. 1423.) The reviewing court concluded that "the parents, who were developmentally disabled, did not receive reasonable family reunification services" (id. at p. 1419) and granted writ relief. (Id. at pp. 1428-1429.) In In re Elizabeth R. (1995) 35 Cal.App.4th 1774, the issue was "whether the juvenile court was compelled by law to terminate reunification services and order a section 366.26 hearing at the 18-month review hearing when a parent, although hospitalized for treatment of her mental illness for most of the reunification period, had substantially complied with the reunification plan." (Elizabeth R., supra, 35 Cal.App.4th at p. 1787.) The court determined that the juvenile court had "discretion to accommodate the special needs of the family of the mentally ill in the unusual circumstances presented by this case." (Ibid.) The Legislature has established a comprehensive statutory framework governing provision of reunification services and extension of the reunification period. (See 361.5; see also 366.21, 366.22, 366.25.) In In re Elizabeth R. (1995) the juvenile court reluctantly terminated reunification services at the 18-month review hearing for a mentally ill mother who had an "impeccable record of visitation and efforts to comply with the reunification plan," but her efforts were unsuccessful because she was hospitalized for all but five months of the reunification phase of the dependency proceedings. (Id. at pp. 1777-1778.) Though impressed with the mother's progress and ability to sustain her mental health, the court believed it had no choice but to terminate reunification services. (Id. at p. 1783.) On appeal, the case was remanded for the juvenile court to entertain a section 352 motion for a continuance of services beyond the statutory limitation. (Elizabeth R., supra, 35 Cal.App.4th at p. 1799.) The appellate court concluded "section 352 provides an emergency escape valve in those rare instances" in which the juvenile court determines the best interests of the child would be served by a continuance of a review hearing beyond the statutorily permissible time frame. (Id. at pp. 1798-1799.)