Orange County Social Services Agency v. Albert Z.

INTRODUCTION

Albert Z. (Father) appealed from the juvenile court’s order terminating his parental rights to his daughter, then two-year-old A.Z. Father contended the *1179 juvenile court erred by finding inapplicable the parent-child relationship exception to the termination of parental rights under Welfare and Institutions Code section 366.26, subdivision (c)(l)(B)(i). In his appellate briefs, Father asserted, inter alia, his concern that A. “would lose eligibility for disability and Veteran’s Administration benefits that she would be entitled to through [him]” if his parental rights were terminated.

During the pendency of this appeal, Father’s counsel informed this court of Father’s death and filed a motion to dismiss the appeal as moot. We appointed counsel to represent A. and invited all parties to file supplemental briefs addressing the proper resolution of this appeal in light of A.’s best interests. For the reasons we explain, we dismiss the appeal as moot. We publish this opinion because the parties have not cited, and we have not found, any published opinion addressing the proper disposition of a dependency appeal when an appellant parent dies while the appeal…