Los Angeles County Department of Children & Family Services v. Anna O.

This juvenile dependency case involves two appeals. Anna O. (Anna), the maternal grandmother of Jacob E. (Jacob), appeals from two juvenile court orders. She challenges the juvenile court’s order denying her application for de facto parent status on the grounds that the juvenile court improperly applied the relevant criteria by failing to take into account the lengthy period of time that she cared for Jacob in the role of his parent. Anna also contends that the juvenile court abused its discretion by failing to hold a hearing before the Department of Children and Family Services (the Department) removed Jacob from her care. Finding no abuse of discretion, we affirm the juvenile court’s orders.

The Department appeals the juvenile court’s order appointing counsel for Jacob’s birth mother (mother) at the hearing on Anna’s application for de facto parent status. The Department contends that because mother’s parental rights had been terminated more than two and one-half years before the hearing, there was no statutory basis upon which to appoint counsel. We agree. Welfare and Institutions Code section 317 1 provides for the appointment of counsel to a parent or guardian.…