Danielle Downing appeared in a Visalia courtroom Thursday afternoon for the custody hearing of her three-year-old son.
In October, Farmersville Police discovered a dead baby in a trash can at her house. Police say the newborn baby girl was Downing's.
Downing has not been charged with any crime and police say they have no update to the investigation.
Downing's ex-boyfriend, Jeremy Estes, has full custody of their three-year-old boy.
