In re Caden C.

Summary

The court held that the parental-benefit exception requires proof of regular visitation, a substantial positive emotional attachment benefiting the child, and detriment from terminating that attachment even after considering the benefits of adoption. A parent's continuing substance-abuse or mental-health problems are not a categorical bar and may be considered only insofar as they bear on those statutory questions. The court also adopted a mixed standard of review and reversed the Court of Appeal, directing dismissal of the appeal as moot because a later proceeding had terminated parental rights.