San Diego County Department of Social Services v. Victor E.

Victor E. appeals after the court denied de facto parent status to Victor’s mother and sisters in this dependency proceeding involving Victor’s child, Vanessa Z. Victor contends the court abused its discretion because his mother and sisters met the criteria for de facto parents and no interest was furthered by denying them that status. We conclude Victor lacks standing to challenge the order because his interests are not prejudiced by the denial of de facto parent status to his relatives. Accordingly we affirm the order.

Factual and Procedural Background

Vanessa tested positive for cocaine at birth on December 15, 1991. The court declared Vanessa a dependent on January 21, 1992, due to her mother’s 1 drug use and Victor’s failure to protect her. (Welf. & Inst. Code 2 § 300, subd. (b)) Victor was on probation for possession of a controlled substance. He stated he was unable to care for Vanessa but wanted her to be placed with his mother, Maria E.

After evaluating Maria’s home, the department of social services (Department) recommended against placing Vanessa with Maria. Maria had 10 prior *260 referrals to child protective services concerning 5 of her own children. She…