In re J.B., 2011 Ohio 4830

CCDCFS filed abuse/neglect petition for J.B. and sought temporary custody; J.B. was placed in agency custody and later deemed neglected and dependent.
Gallagher foster parents began caring for J.B. and filed motions to intervene and for legal custody.
Maternal relatives also sought legal custody; CCDCFS moved for permanent custody under R.C. 2151.414.
Trial court held a hearing on intervention and custody petitions; Gallaghers’ motions were denied.
Gallaghers appealed, arguing they had standing to intervene, notice deficiencies, and that their custody motion should have been heard.
The appellate court affirms, holding Gallaghers lack standing to intervene in a permanent custody proceeding.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Do Gallaghers have standing to intervene in a permanent custody action?	Gallaghers contend they are interested persons who should have party status.	Court should rely on Juv.R. 2(Y) and existing precedent limiting foster parents' standing in permanent custody cases.	No standing; intervention denied.
Was notice to Gallaghers proper, and did lack of notice prejudice them?	Gallaghers argue they were entitled to notice and to present evidence.	Notice issue is moot because Gallaghers lacked standing to intervene.	Issue deemed meritless; no prejudice shown.
Should the court have dismissed the custody motion without a hearing if Gallaghers lacked standing?	Gallaghers claim dismissal without a hearing denied them process.	Without standing, intervention and custody motion can be disposed of without a hearing.	No reversible error; dismissal upheld.

In re C.J. & M.B., 2010-Ohio-3202 (Ohio App. 8th Dist. 2010) (standing of an interested person in juvenile custody governs intervention)
Renfro v. Cuyahoga Cty. Dept. of Human Serv., 884 F.2d 943 (6th Cir. 1989) (foster parents have limited rights; no constitutionally protected liberty interest)