San Mateo County Human Services Agency v. Juanita I.

De facto parents occupy a grey zone in dependency proceedings. They are not parties in the strict and pure sense of that term, but they are afforded many of the same privileges and opportunities. The sole issue presented here is whether it was prejudicial error for the juvenile court to deny the request of the de facto parents of twin boys the opportunity to call and cross-examine witnesses at an 18-month review hearing where the court would decide whether to return the twins to their mother. In the distinct circumstances confronting the juvenile court, we conclude there is no basis for reversal.

BACKGROUND

The nature of the issue we must address does not require an extensive recapitulation of the historical details of the entire dependency. The salient background can be reduced to the following:

The minors, Damion and Dominick, are twins, born to parents with pronounced substance abuse problems. Dominick was bom with a cleft Up and palate, and was later diagnosed with cerebral palsy. Virtually from their premature birth in June 2009, the minors were on the radar of the San Mateo County Human Services Agency (Agency). Very soon after their birth, the minors were…