In re M.M. CA6

I. INTRODUCTION

M.M. is the child at issue in this juvenile dependency case. At the jurisdiction/disposition hearing held on June 6, 2014, the juvenile court bypassed reunification services to her mother, J.M., and set a Welfare and Institutions Code section 366.261 permanency planning hearing. At the June 6, 2014 hearing, the juvenile court also denied a number of section 388 petitions and a request for de facto parent status filed by the maternal grandmother, L.M. The mother and the maternal grandmother both previously filed petitions for extraordinary writs seeking review of the juvenile court’s orders at the June 6, 2014 hearing. This court denied those petitions in an opinion filed on September 11, 2014. (J.M. v. Superior Court (Sept. 11, 2014, H041083) [nonpub. opn.].) The maternal grandmother also filed a notice of appeal following the June 6, 2014 hearing. The mother did not file a notice of appeal. In this opinion, we determine that the maternal grandmother lacks standing to raise claims on behalf of the mother, and that the law of the case doctrine precludes us from reconsidering the claims the maternal grandmother raises on behalf of herself. We will therefore…