A.G., In re (2020) H047951 H047951; filed 12/18/20. ![[Files/CaseFiles/H047951.PDF]] [Opinion PDF](https://www.courts.ca.gov/opinions/archive/H047951.PDF) ## Rule excerpts Procedural sufficiency of an offer of proof for a contested section 366.26 hearing; quoting In re Grace P. (2017) 8 Cal.App.5th 605, 615 and In re Tamika T. (2002) 97 Cal.App.4th 1114, 1124. For the later substantive parental-benefit standard, see In re Caden C. (2021) 11 Cal.5th 614. > Given the stakes at issue to the parent—the potential termination of his or her parental rights—the juvenile court “must take caution before denying a contested hearing” on the parental relationship exception (Grace P., supra, at p. 615, italics added), and it should construe the parent’s offer of proof liberally in favor of allowing such a hearing. (Cf. In re Marilyn H., supra, at p. 309 [parent’s petition under § 388 for change of order should “be liberally construed in favor of granting a hearing to consider the parent's request”].) Additionally, because of this dependency context, we believe that the principle applicable to offers of proof generally that permits the rejection of an offer of proof “where it consists in part of irrelevant matter” (Byrd v. Savage (1963) 219 Cal.App.2d 396, 402) is not appropriate in the evaluation of a parent’s offer of proof in support of an adoption exception. If the parent’s proffer is “specific, setting forth the actual evidence to be produced, not merely the facts or issues to be addressed and argued” (Tamika T., supra, 97 Cal.App.4th at p. 1124), the parent should not be deprived of an evidentiary hearing simply because the offer of proof also includes irrelevant matter. — A.G., In re (2020) H047951, slip op., p. 40.