H.V. v. State, 376 P.3d 1077

In December 2014 Guardian was granted permanent custody and guardianship of Z.G. after the child was adjudicated neglected by her mother.
Child was removed from Guardian's custody multiple times in early 2015; Guardian was arrested on drug charges and her mother could not provide long-term care.
DCFS filed a verified petition; the juvenile court adjudicated the child neglected by Guardian and placed custody with DCFS.
Child’s guardian ad litem moved to deny reunification services for Guardian; the juvenile court ruled Guardian lacked standing to seek services and alternatively held reunification would not be in the child’s best interests.
Guardian appealed, arguing the juvenile court erred on standing; the State conceded standing was the better interpretation but argued the denial was within the court’s discretion.
The Court of Appeals held permanent guardians have standing to seek reunification services but affirmed the juvenile court’s denial on best-interest grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a permanent guardian has standing to seek reunification services	Guardian: permanent guardianship confers standing to request services when the child is removed	State: while the parties agreed standing is plausible, the juvenile court found no standing	Court: Yes — permanent guardians have standing to seek reunification services
Whether juvenile court abused its discretion by denying reunification services	Guardian: remand to determine whether services should be granted	State: denial was discretionary and appropriate given facts	Court: No — denial was within discretion; reunification not in child’s best interests
Whether permanent guardians retain other "residual rights" after removal	Guardian: asserts residual parental-like rights remain (arg on appeal undeveloped)	State: did not fully litigate; juvenile court did not decide	Court: Issue unpreserved/undeveloped; not decided on appeal

Davis County Solid Waste Mgmt. & Energy Recovery Special Serv. Dist. v. City of Bountiful, 52 P.3d 1174 (Utah 2002) (statutory interpretation principles and harmonization of provisions)
In re S.F., 268 P.3d 831 (Utah Ct. App. 2012) (standards of review for statutory interpretation in juvenile cases)
In re N.R., 967 P.2d 951 (Utah Ct. App. 1998) (no absolute right to reunification services; discretionary review)
In re T.S., 927 P.2d 1124 (Utah Ct. App. 1996) (left open whether permanent guardians may have parent-like rights)
In re A.T., 353 P.3d 131 (Utah 2015) (reunification services only required when implicated by the primary permanency plan)