CLIFFORD S. v. Superior Court

This case presents the issue of whether a de facto parent has standing to challenge the denial of reunification services or contest the reasonableness of services offered. Because a de facto parent, like a stepparent, has no right to reunification services, we conclude that a de facto parent lacks standing to raise reunification issues.

Factual and Procedural Background

Clifford S. and his wife, Rita, have four children together; Rita has three children by previous relationships, including Chantella, the minor in question here. The department of social services (Department) filed a dependency petition on August 6, 1993, alleging Chantella had suffered accidental bums several months earlier and had not received proper medical care. An allegation the other children were at risk was dismissed. The matter was submitted, and the petition was sustained on August 19, 1993.

According to the social services report for the dispositional hearing on September 15, 1993, a parent search had been initiated the preceding month for Chantella’s presumed father, Jack L. The Department also reported that because Rita now suggested Clifford might be Chantella’s father, a paternity test was…