In Re Wlh, 314 Ga. App. 185

DFACS filed a deprivation action alleging lack of proper care for 12-year-old W.L.H., who had been in his guardians’ custody since about 17 months old.
The guardians were Marian and John Helsinger; the child’s natural father is deceased and the mother’s whereabouts were unknown.
A shelter care order was entered on August 9, 2010, after the guardians admitted striking the child despite a safety plan prohibiting physical discipline.
A CASA guardian ad litem was appointed, attended the 72-hour hearing, and provided monthly recommendations; DFACS filed a deprivation petition on September 16, 2010, and a case plan followed.
The court appointed a child’s counsel on September 15, 2010; hearings occurred October and November 2010 with ongoing debate over the child’s status as a party and his right to be present.
The court ultimately excluded the child from the proceedings on the first day and again on the second day; the child sought access in a motion, which the court denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the child has standing to appeal without a guardian or next friend	W.L.H. lacked standing to appeal on his own.	Guardian ad litem represents the child and may appeal; standing exists.	Child lacks standing to appeal without a guardian or next friend.

St. John's Melkite Catholic Church v. Comm. of Revenue, 240 Ga. 733 (1978) (courts may raise standing sua sponte)
In the Interest of J.F., 310 Ga.App. 807 (2011) (guardian ad litem provides standing to appeal for represented minor)
Kesterson v. Jarrett, 307 Ga.App. 244 (2010) (minor may proceed via representative; OCGA 9-11-17(c))
City of Dalton v. Cochran, 80 Ga.App. 252 (1949) (guardian ad litem/next friend represents minor in litigation)
In the Interest of M.B.B., 241 Ga.App. 249 (1999) (proper party through guardian ad litem to contest ruling)
Miller v. Rieser, 213 Ga.App. 683 (1994) (minor has standing through guardian ad litem in custody actions)