San Diego Cnty. Health & Human Servs. Agency v. M.M. (In re Charlotte C.)

*408 Implemented statewide on January 1, 2017, the Resource Family Approval Program (RFA) provides a unified approval process to replace the multiple processes to approve foster care homes, relatives and nonrelative extended family members, and adoptive homes for the placement of dependent children. The RFA process involves the comprehensive collection and review of an applicant's personal information. The RFA contains a number of provisions designed to guarantee that the collected information remains confidential, with only limited exceptions. Those specific statutory exceptions do not explicitly include the release of RFA information to minor's counsel.

Raising an issue of first impression, minor Charlotte C. contends the juvenile court erred in denying her counsel's request for her relatives' RFA assessment information. She argues a number of statutory *102 and regulatory exceptions allow minor's counsel to access such information, including Welfare and Institutions Code, section 317 1 which grants minor's counsel access to all public agency records relevant to the child's case. Charlotte asserts minor's counsel has an obligation to review her relative's RFA *409 information…