In Re KC, 128 Cal. Rptr. 3d 276

K.C. is the youngest of eight; father’s parental rights were terminated in a prior proceeding; grandparents sought placement for K.C. with them; agency denied placement citing concerns incl. access, caregiver capacity, and a prior suicide in the family home; the juvenile court bypassed reunification efforts and scheduled a dependency termination hearing; grandparents petitioned under §388 to modify placement; at the contested hearing, agency opposed, grandparents supportive, father urged placement with grandparents but did not contest termination; mother incarcerated and did not appear; the juvenile court denied the §388 petition, adopted adoption as permanent plan, and terminated parental rights; father appealed but did not challenge the termination and instead argued about placement; the Court of Appeal dismissed for lack of standing; the Supreme Court granted review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a parent whose rights have been terminated has standing to appeal a placement order.	Agency argued father lacks standing; once rights terminated, interests no longer aggrieved.	Father contends placement order could affect his status and rights, potentially challenging termination.	Father lacks standing; no aggrieved interest after termination to appeal placement order.

In re L. Y. L., 101 Cal.App.4th 942 (2002) (standing requires aggrieved status; broadstanding does not apply to dependency appeals)
In re Marilyn H., 5 Cal.4th 295 (1993) (parents have interest in care of child; but focus shifts to child's needs after reunification is bypassed)
In re Nolan W., 45 Cal.4th 1217 (2009) (dependency priorities; reunification focus; permanency planning)
In re A.M., 164 Cal.App.4th 914 (2008) (parental rights termination context; placement decisions and standing considerations)
In re H.G., 146 Cal.App.4th 1 (2006) (standing where termination could be affected by placement order; relative placement analysis)
In re Esperanza C., 165 Cal.App.4th 1042 (2008) (extension of H.G. rationale to §388 placement petitions; potential to affect termination decision)
In re Cesar V. v. Superior Court, 91 Cal.App.4th 1023 (2001) (parent who litigates below may support an appellee; not a standing holding)
In re Carissa G., 76 Cal.App.4th 731 (1999) (participation on issue does not by itself grant standing to appeal)
County of Alameda v. Carleson, 5 Cal.3d 730 (1971) (standing requires aggrieved status; not mere participation)
Estate of Colton, 164 Cal. 1 (1912) (standing concept foundational; aggrieved party rule)