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18 California opinions name it 3 courts 1993–2025 3 in the last five years
The cases below were cited by California courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
In Re Kieshia E.green2 sentences2025The order changing physical custody was within the sound 6 “In In re Kieshia E. (1993) 6 Cal.4th 68 , the California Supreme Court clarified that a de facto parent’s standing is limited by the rationale underlying the de facto parent doctrine itself: ‘The de facto parenthood doctrine simply recognizes that persons who have provided a child with daily parental concern, affection, and care over substantial time may develop legitimate interests and perspectives, and may also present a custodial alternative, which should not be ignored in a juvenile dependency proceeding. 2025Applicable Law and Standard of Review “De facto parent status is ordinarily liberally granted on the theory that a court only benefits from having all relevant information on the best interests of the child.” (In re Bryan D. (2011) 199 Cal.App.4th 127, 141 .) “The concept of de facto parent has been judicially created to recognize limited rights in dependency cases for a person who has been found by the juvenile court to have assumed, on a day-to-day basis, the role of a parent, fulfilling the child’s physical and psychological needs. [Citations.] (In re Leticia S. (2001) 92 Cal.App.4th 378, 3 | 4 | 12 |
In Re Leticia S.green2 sentences2025Applicable Law and Standard of Review “De facto parent status is ordinarily liberally granted on the theory that a court only benefits from having all relevant information on the best interests of the child.” (In re Bryan D. (2011) 199 Cal.App.4th 127, 141 .) “The concept of de facto parent has been judicially created to recognize limited rights in dependency cases for a person who has been found by the juvenile court to have assumed, on a day-to-day basis, the role of a parent, fulfilling the child’s physical and psychological needs. [Citations.] (In re Leticia S. (2001) 92 Cal.App.4th 378, 3 2016When a juvenile court 15 has found that the nonparent committed such abuse, and has therefore deemed it necessary to make the victim a dependent of the court, the abuser is barred from intervening in the same proceeding under the de facto parenthood doctrine.” (Id. at pp. 79-80; see also In re Merrick V., supra, 122 Cal.App.4th at pp. 256-258 [grandmother not entitled to de facto parent status where she indirectly caused dependency by leaving the children with their drug-using mother]; In re Leticia S. (2001) 92 Cal.App.4th 378, 382-383 [mother’s boyfriend not entitled to de facto parent statu | 3 | 3 |
In Re BGgreen2 sentences2008G. (1974) 11 Cal.3d 679 [ 114 Cal.Rptr. 444 , 523 P.2d 244 ] that “de facto parents, such as . . . foster parents . . . , should be permitted to appear as parties in juvenile court proceedings ... to assert and protect their own interest in the companionship, care, custody, and management of the child.” (Id. at p. 693.) However, as the court later explained in In re Kieshia E. (1993) 6 Cal.4th 68 [ 23 Cal.Rptr.2d 775 , 859 P.2d 1290 ], that standing is limited by the rationale underlying the de facto parent doctrine itself: “The de facto parenthood doctrine simply recognizes that persons who h 2008G. (1974) 11 Cal.3d 679 [ 114 Cal.Rptr. 444 , 523 P.2d 244 ] that “de facto parents, such as . . . foster parents . . . , should be permitted to appear as parties in juvenile court proceedings ... to assert and protect their own interest in the companionship, care, custody, and management of the child.” (Id. at p. 693.) However, as the court later explained in In re Kieshia E. (1993) 6 Cal.4th 68 [ 23 Cal.Rptr.2d 775 , 859 P.2d 1290 ], that standing is limited by the rationale underlying the de facto parent doctrine itself: “The de facto parenthood doctrine simply recognizes that persons who h | 2 | 7 |
In Re Rachael C.green2 sentences1993In re B.G., supra , expressly declined to hold that nonparents who assume a parental role thereby become "parents" or "guardians," with all the rights such a status implies. (11 Cal.3d at p. 693, fn. 21.) (3)(See fn. 7.), (1b) Subsequent Court of Appeal decisions have confirmed that even those who attain the status of de facto parenthood "are not equated with ... parents or guardians for purposes of dependency proceedings and standing to participate does not give them all of the rights and preferences accorded [parents or guardians]. [Citations.]...." ( In re Rachael C. (1991) 235 Cal. App.3d 1993In re B.G., supra , expressly declined to hold that nonparents who assume a parental role thereby become "parents" or "guardians," with all the rights such a status implies. (11 Cal.3d at p. 693, fn. 21.) (3)(See fn. 7.), (1b) Subsequent Court of Appeal decisions have confirmed that even those who attain the status of de facto parenthood "are not equated with ... parents or guardians for purposes of dependency proceedings and standing to participate does not give them all of the rights and preferences accorded [parents or guardians]. [Citations.]...." ( In re Rachael C. (1991) 235 Cal. App.3d | 2 | 3 |
In Re Jody R.green2 sentences1993In re B.G., supra , expressly declined to hold that nonparents who assume a parental role thereby become "parents" or "guardians," with all the rights such a status implies. (11 Cal.3d at p. 693, fn. 21.) (3)(See fn. 7.), (1b) Subsequent Court of Appeal decisions have confirmed that even those who attain the status of de facto parenthood "are not equated with ... parents or guardians for purposes of dependency proceedings and standing to participate does not give them all of the rights and preferences accorded [parents or guardians]. [Citations.]...." ( In re Rachael C. (1991) 235 Cal. App.3d 1993In re B.G., supra , expressly declined to hold that nonparents who assume a parental role thereby become "parents" or "guardians," with all the rights such a status implies. (11 Cal.3d at p. 693, fn. 21.) (3)(See fn. 7.), (1b) Subsequent Court of Appeal decisions have confirmed that even those who attain the status of de facto parenthood "are not equated with ... parents or guardians for purposes of dependency proceedings and standing to participate does not give them all of the rights and preferences accorded [parents or guardians]. [Citations.]...." ( In re Rachael C. (1991) 235 Cal. App.3d | 2 | 2 |
Los Angeles County Department of Children & Family Services v. T.D.green2 sentences2025Applicable Law and Standard of Review “De facto parent status is ordinarily liberally granted on the theory that a court only benefits from having all relevant information on the best interests of the child.” (In re Bryan D. (2011) 199 Cal.App.4th 127, 141 .) “The concept of de facto parent has been judicially created to recognize limited rights in dependency cases for a person who has been found by the juvenile court to have assumed, on a day-to-day basis, the role of a parent, fulfilling the child’s physical and psychological needs. [Citations.] (In re Leticia S. (2001) 92 Cal.App.4th 378, 3 2025(In re Vincent C. (1997) 53 Cal.App.4th 1347, 1358 .) A de facto parent has “‘procedural rights’ in the ongoing dependency proceedings, such as the right to be present at hearings, to be heard and to retain counsel,” but the de facto parent does not have “ any substantive rights to ‘reunification services, . . . custody, [or] continued placement of the child.’” (In re Brianna S. (2021) 60 Cal.App.5th 303 , 314, italics omitted; see Cal. Rules of Court, rule 5.534(a).) When ruling on a de facto parent request, “the court does not consider whether the order would be . . . in [the child’s] best i | 1 | 2 |
In Re Hirenia C.green2 sentences2014(Ibid.) “The de facto parenthood doctrine simply recognizes that persons who have provided a child with daily parental concern, affection, and care over substantial time may develop legitimate interests and perspectives, and may also present a custodial alternative, which should not be ignored in a juvenile dependency proceeding.” (Ibid.) We review the juvenile court’s denial of a request for de facto parent status for substantial evidence.4 (In re Ashley P. (1998) 62 Cal.App.4th 23, 26-30 .) “[T]he concept of de facto parenthood must be applied liberally.” (In re Hirenia C. (1993) 18 Cal.App. 1998Above all, the decision depends on the particular individual seeking such status and the unique circumstances of the case. ( In re Patricia L. (1992) 9 Cal. App.4th 61, 66-67 [ 11 Cal. Rptr.2d 631 ].) As several courts have observed, the juvenile court can only benefit from having all relevant information bearing on the best interests of the child, and de facto status should be liberally granted. ( In re Hirenia C. (1993) 18 Cal. App.4th 504, 514 [ 22 Cal. Rptr.2d 443 ]; In re Patricia L., supra, 9 Cal. App.4th at p. 67 .) "The simple fact that a person cares enough to seek and undertake to pa | 1 | 2 |
Sharon S. v. Superior Courtgreen2 sentences2003Such duplication hardly would constitute the "prompt resolution of adoption proceedings" ( Adoption of Kelsey S., supra, 1 Cal.4th at p. 851 , 4 Cal.Rptr.2d 615 , 823 P.2d 1216 ) on which we consistently have placed a priority. [25] "The de facto parenthood doctrine simply recognizes that persons who have provided a child with daily parental concern, affection, and care over substantial time may develop legitimate interests and perspectives, and may also present a custodial alternative, which should not be ignored in a juvenile dependency proceeding." ( In re Kieshia E. (1993) 6 Cal.4th 68, 77 2003Such duplication hardly would constitute the "prompt resolution of adoption proceedings" ( Adoption of Kelsey S., supra, 1 Cal.4th at p. 851 , 4 Cal.Rptr.2d 615 , 823 P.2d 1216 ) on which we consistently have placed a priority. [25] "The de facto parenthood doctrine simply recognizes that persons who have provided a child with daily parental concern, affection, and care over substantial time may develop legitimate interests and perspectives, and may also present a custodial alternative, which should not be ignored in a juvenile dependency proceeding." ( In re Kieshia E. (1993) 6 Cal.4th 68, 77 | 1 | 1 |
In Re Patricia L.green2 sentences1998Above all, the decision depends on the particular individual seeking such status and the unique circumstances of the case. ( In re Patricia L. (1992) 9 Cal. App.4th 61, 66-67 [ 11 Cal. Rptr.2d 631 ].) As several courts have observed, the juvenile court can only benefit from having all relevant information bearing on the best interests of the child, and de facto status should be liberally granted. ( In re Hirenia C. (1993) 18 Cal. App.4th 504, 514 [ 22 Cal. Rptr.2d 443 ]; In re Patricia L., supra, 9 Cal. App.4th at p. 67 .) "The simple fact that a person cares enough to seek and undertake to pa 1998Above all, the decision depends on the particular individual seeking such status and the unique circumstances of the case. ( In re Patricia L. (1992) 9 Cal. App.4th 61, 66-67 [ 11 Cal. Rptr.2d 631 ].) As several courts have observed, the juvenile court can only benefit from having all relevant information bearing on the best interests of the child, and de facto status should be liberally granted. ( In re Hirenia C. (1993) 18 Cal. App.4th 504, 514 [ 22 Cal. Rptr.2d 443 ]; In re Patricia L., supra, 9 Cal. App.4th at p. 67 .) "The simple fact that a person cares enough to seek and undertake to pa | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in California. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
In Re Jacob E.
green
2 sentences2025(In re Vincent C. (1997) 53 Cal.App.4th 1347, 1358 .) A de facto parent has “‘procedural rights’ in the ongoing dependency proceedings, such as the right to be present at hearings, to be heard and to retain counsel,” but the de facto parent does not have “ any substantive rights to ‘reunification services, . . . custody, [or] continued placement of the child.’” (In re Brianna S. (2021) 60 Cal.App.5th 303 , 314, italics omitted; see Cal. Rules of Court, rule 5.534(a).) When ruling on a de facto parent request, “the court does not consider whether the order would be . . . in [the child’s] best i 2016For example, in In re Jacob E. (2004) 121 Cal.App.4th 909 , the child (Jacob) was declared a dependent because the mother was abusing methamphetamine. | 3 | 2014–2025 |
In Re Pl
green
2 sentences2021The standing accorded de facto parents has no basis independent of these concerns.” (Id. at pp. 77-78, italics added.) “De facto parents are not equated with biological parents or guardians for purposes of dependency proceedings and standing to participate does not give them all of the rights and preferences accorded such persons.” (In re Rachael C. (1991) 235 Cal.App.3d 1445, 1452 , disapproved on other grounds in Kieshia E., supra, 6 Cal.4th at p. 80 .) De facto parent status does not give the de facto parent the right to reunification services, visitation, custody, or placement of the minor 2008The standing accorded de facto parents has no basis independent of these concerns.” (Id. at pp. 77-78.) The only cases cited by the majority which concern the de facto parents’ right to appeal a dependency court order are In re Joel H., supra, 19 Cal.App.4th 1185 and In re P.L. (2005) 134 Cal.App.4th 1357 [ 37 Cal.Rptr.3d 6 ]. | 3 | 2008–2021 |
In Re Vincent C.
green
2 sentences2025(In re Vincent C. (1997) 53 Cal.App.4th 1347, 1358 .) A de facto parent has “‘procedural rights’ in the ongoing dependency proceedings, such as the right to be present at hearings, to be heard and to retain counsel,” but the de facto parent does not have “ any substantive rights to ‘reunification services, . . . custody, [or] continued placement of the child.’” (In re Brianna S. (2021) 60 Cal.App.5th 303 , 314, italics omitted; see Cal. Rules of Court, rule 5.534(a).) When ruling on a de facto parent request, “the court does not consider whether the order would be . . . in [the child’s] best i 2017The fundamental case recognizing de facto parenthood, In re B.G ., supra , 11 Cal.3d 679 , 114 Cal.Rptr. 444 , 523 P.2d 244 , on which they rely, recognized foster parents' standing to appear in juvenile court proceedings, not grandparent *915 visitation rights outside of dependency proceedings. ( Id. at p. 693, 114 Cal.Rptr. 444 , 523 P.2d 244 .) We decline to consider out-of-state decisions ( Episcopal Church Cases (2009) 45 Cal.4th 467 , 490, 87 Cal.Rptr.3d 275 , 198 P.3d 66 ), and the California authorities Ed and Yvonne cite ( In re Ashley P. (1998) 62 Cal.App.4th 23 , 72 Cal.Rptr.2d 383 | 2 | 2017–2025 |
In Re Ashley P.
green
2 sentences2017The fundamental case recognizing de facto parenthood, In re B.G ., supra , 11 Cal.3d 679 , 114 Cal.Rptr. 444 , 523 P.2d 244 , on which they rely, recognized foster parents' standing to appear in juvenile court proceedings, not grandparent *915 visitation rights outside of dependency proceedings. ( Id. at p. 693, 114 Cal.Rptr. 444 , 523 P.2d 244 .) We decline to consider out-of-state decisions ( Episcopal Church Cases (2009) 45 Cal.4th 467 , 490, 87 Cal.Rptr.3d 275 , 198 P.3d 66 ), and the California authorities Ed and Yvonne cite ( In re Ashley P. (1998) 62 Cal.App.4th 23 , 72 Cal.Rptr.2d 383 2014(Ibid.) “The de facto parenthood doctrine simply recognizes that persons who have provided a child with daily parental concern, affection, and care over substantial time may develop legitimate interests and perspectives, and may also present a custodial alternative, which should not be ignored in a juvenile dependency proceeding.” (Ibid.) We review the juvenile court’s denial of a request for de facto parent status for substantial evidence.4 (In re Ashley P. (1998) 62 Cal.App.4th 23, 26-30 .) “[T]he concept of de facto parenthood must be applied liberally.” (In re Hirenia C. (1993) 18 Cal.App. | 2 | 2014–2017 |
In Re Joel H.
green
2 sentences2008The standing accorded de facto parents has no basis independent of these concerns.” (Id. at pp. 77-78.) The only cases cited by the majority which concern the de facto parents’ right to appeal a dependency court order are In re Joel H., supra, 19 Cal.App.4th 1185 and In re P.L. (2005) 134 Cal.App.4th 1357 [ 37 Cal.Rptr.3d 6 ]. 2008The standing accorded de facto parents has no basis independent of these concerns." ( Id. at pp. 77-78, 23 Cal. Rptr.2d 775 , 859 P.2d 1290 .) The only cases cited by the majority which concern the de facto parents' right to appeal a dependency court order are In re Joel H., supra, 19 Cal.App.4th 1185 , 23 Cal.Rptr.2d 878 and In re P.L. (2005) 134 Cal.App.4th 1357 , 37 Cal.Rptr.3d 6 . | 2 | 2008–2008 |
In Re Cynthia C.
green
1 sentence2021The standing accorded de facto parents has no basis independent of these concerns.” (Id. at pp. 77-78, italics added.) “De facto parents are not equated with biological parents or guardians for purposes of dependency proceedings and standing to participate does not give them all of the rights and preferences accorded such persons.” (In re Rachael C. (1991) 235 Cal.App.3d 1445, 1452 , disapproved on other grounds in Kieshia E., supra, 6 Cal.4th at p. 80 .) De facto parent status does not give the de facto parent the right to reunification services, visitation, custody, or placement of the minor | 1 | 2021–2021 |
CLIFFORD S. v. Superior Court
green
1 sentence2021The standing accorded de facto parents has no basis independent of these concerns.” (Id. at pp. 77-78, italics added.) “De facto parents are not equated with biological parents or guardians for purposes of dependency proceedings and standing to participate does not give them all of the rights and preferences accorded such persons.” (In re Rachael C. (1991) 235 Cal.App.3d 1445, 1452 , disapproved on other grounds in Kieshia E., supra, 6 Cal.4th at p. 80 .) De facto parent status does not give the de facto parent the right to reunification services, visitation, custody, or placement of the minor | 1 | 2021–2021 |
CHRISTINA K. v. Superior Court
green
2 sentences2017The fundamental case recognizing de facto parenthood, In re B.G ., supra , 11 Cal.3d 679 , 114 Cal.Rptr. 444 , 523 P.2d 244 , on which they rely, recognized foster parents' standing to appear in juvenile court proceedings, not grandparent *915 visitation rights outside of dependency proceedings. ( Id. at p. 693, 114 Cal.Rptr. 444 , 523 P.2d 244 .) We decline to consider out-of-state decisions ( Episcopal Church Cases (2009) 45 Cal.4th 467 , 490, 87 Cal.Rptr.3d 275 , 198 P.3d 66 ), and the California authorities Ed and Yvonne cite ( In re Ashley P. (1998) 62 Cal.App.4th 23 , 72 Cal.Rptr.2d 383 2017The fundamental case recognizing de facto parenthood, In re B.G ., supra , 11 Cal.3d 679 , 114 Cal.Rptr. 444 , 523 P.2d 244 , on which they rely, recognized foster parents' standing to appear in juvenile court proceedings, not grandparent *915 visitation rights outside of dependency proceedings. ( Id. at p. 693, 114 Cal.Rptr. 444 , 523 P.2d 244 .) We decline to consider out-of-state decisions ( Episcopal Church Cases (2009) 45 Cal.4th 467 , 490, 87 Cal.Rptr.3d 275 , 198 P.3d 66 ), and the California authorities Ed and Yvonne cite ( In re Ashley P. (1998) 62 Cal.App.4th 23 , 72 Cal.Rptr.2d 383 | 1 | 2017–2017 |
Episcopal Church Cases
green
2 sentences2017The fundamental case recognizing de facto parenthood, In re B.G ., supra , 11 Cal.3d 679 , 114 Cal.Rptr. 444 , 523 P.2d 244 , on which they rely, recognized foster parents' standing to appear in juvenile court proceedings, not grandparent *915 visitation rights outside of dependency proceedings. ( Id. at p. 693, 114 Cal.Rptr. 444 , 523 P.2d 244 .) We decline to consider out-of-state decisions ( Episcopal Church Cases (2009) 45 Cal.4th 467 , 490, 87 Cal.Rptr.3d 275 , 198 P.3d 66 ), and the California authorities Ed and Yvonne cite ( In re Ashley P. (1998) 62 Cal.App.4th 23 , 72 Cal.Rptr.2d 383 2017The fundamental case recognizing de facto parenthood, In re B.G ., supra , 11 Cal.3d 679 , 114 Cal.Rptr. 444 , 523 P.2d 244 , on which they rely, recognized foster parents' standing to appear in juvenile court proceedings, not grandparent *915 visitation rights outside of dependency proceedings. ( Id. at p. 693, 114 Cal.Rptr. 444 , 523 P.2d 244 .) We decline to consider out-of-state decisions ( Episcopal Church Cases (2009) 45 Cal.4th 467 , 490, 87 Cal.Rptr.3d 275 , 198 P.3d 66 ), and the California authorities Ed and Yvonne cite ( In re Ashley P. (1998) 62 Cal.App.4th 23 , 72 Cal.Rptr.2d 383 | 1 | 2017–2017 |
In Re Joshuia S.
green
1 sentence2013(In re Joshuia S. (1988) 205 Cal.App.3d 119, 125 .) 35. | 1 | 2013–2013 |
Steven A. v. Rickie M.
green
2 sentences2003Such duplication hardly would constitute the "prompt resolution of adoption proceedings" ( Adoption of Kelsey S., supra, 1 Cal.4th at p. 851 , 4 Cal.Rptr.2d 615 , 823 P.2d 1216 ) on which we consistently have placed a priority. [25] "The de facto parenthood doctrine simply recognizes that persons who have provided a child with daily parental concern, affection, and care over substantial time may develop legitimate interests and perspectives, and may also present a custodial alternative, which should not be ignored in a juvenile dependency proceeding." ( In re Kieshia E. (1993) 6 Cal.4th 68, 77 2003Such duplication hardly would constitute the "prompt resolution of adoption proceedings" ( Adoption of Kelsey S., supra, 1 Cal.4th at p. 851 , 4 Cal.Rptr.2d 615 , 823 P.2d 1216 ) on which we consistently have placed a priority. [25] "The de facto parenthood doctrine simply recognizes that persons who have provided a child with daily parental concern, affection, and care over substantial time may develop legitimate interests and perspectives, and may also present a custodial alternative, which should not be ignored in a juvenile dependency proceeding." ( In re Kieshia E. (1993) 6 Cal.4th 68, 77 | 1 | 2003–2003 |
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.