M.M., In re (2022) B315997
B315997; filed 7/12/22.
![[Files/CaseFiles/B315997.PDF]]
[Opinion PDF](https://www.courts.ca.gov/opinions/archive/B315997.PDF)
## Rule excerpts
Parental-benefit exception and a belated bonding-study request. The separate ICWA harmless-error reasoning was disapproved to the extent inconsistent with In re Dezi C. (2024) 16 Cal.5th 1112 (slip op., p. 46, fn. 18).
> There was no abuse of discretion in denying mother’s belated request for a bonding study and continuance, on the day of the section 366.26 hearing that had been pending for several months. Mother had not maintained regular visitation, so the parental-benefit exception was inapplicable.
— M.M., In re (2022) B315997, slip op., p. 8.