In this case, the Sixth District reversed and remanded a Monterey County juvenile court’s order after a 366.26 hearing “with directions that it, consistent with this opinion, further consider the legal sufficiency of mother’s offer of proof in support of the beneficial parental relationship exception. The court shall permit further argument and, in its discretion, may allow mother the opportunity to amend her prior offer of proof with any specific evidence she believes she can produce that is consistent with her prior oral and written offers of proof to assist the court’s determination of whether her proffer is ‘specific, setting forth the actual evidence to be evidence to be evidence to be produced, not merely the facts or issues to be addressed and argued the facts or issues to be addressed and argued.’ (Tamika T., supra , 97 Cal. App.4th at p. at p. 1124.)
"If the juvenile court concludes that the denial of a contested hearing is appropriate, in order to permit meaningful appellate review, it shall specify its reasons for determining that mother’s offer of proof is not legally sufficient.”
Read the court's full opinion here.