In re S.B. CA5

California Court of Appeal·Decided May 19, 2026·No. F090501·Unpublished

Opinion

Filed 5/19/26 In re S.B. CA5

NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA FIFTH APPELLATE DISTRICT

In re S.B., a Person Coming Under the Juvenile Court Law.

FRESNO COUNTY DEPARTMENT OF F090501 SOCIAL SERVICES, (Super. Ct. No. 25CEJ300050-1) Plaintiff and Respondent,

v. OPINION R.B.,

Defendant and Appellant.

THE COURT* APPEAL from an order of the Superior Court of Fresno County. Kimberly J. Nystrom-Geist, Judge. R.B., in pro. per., for Defendant and Appellant. Douglas T. Sloan, County Counsel, and Lisa R. Flores, Deputy County Counsel, for Plaintiff and Respondent. -ooOoo-

* Before Hill, P. J., Franson, J. and DeSantos, J. PROCEDURAL AND FACTUAL BACKGROUND On June 2, 2025, R.B. (petitioner) petitioned the juvenile court for access to his granddaughter’s, S.B.’s, case file by filing a Judicial Council form JV-570 (Petition for Access to Juvenile Case File) that requested “Case Information” and all orders and dates of pending hearings (See Welf. & Inst. Code, § 827).1 Petitioner asserted that he has a direct and legitimate interest in the case as S.B.’s grandfather but failed to address the purpose for obtaining the records and cited authority only relevant to attendance at juvenile hearings. He further argued that as a grandparent, the court was required to consider whether to grant him visitation rights. Petitioner also argued that the social worker was required to locate him according to section 309, subdivision (e) and provide him with a copy of Judicial Council form JV-287 (Confidential Information). Petitioner concluded that the failures to place S.B. with relatives and to provide him notice required the court to grant him admission to all subsequent proceedings. Petitioner’s declaration in support of his petition to access the juvenile case file asserted that he has a close and supportive relationship with S.G., he regularly visited her as an infant, and he maintained a close and supportive relationship by phone and in writing when not able to visit.2 The juvenile court denied the petition on June 30, 2025, concluding that access to the juvenile case file, or the records contained therein, was not in the child’s best interests, the need for access did not outweigh the privacy rights of the child and policy considerations favoring confidentiality, and the petition failed to show the requested records were necessary and had substantial relevance to petitioner’s legitimate needs. The juvenile court additionally noted that petitioner’s petition addressed only the rules

1 Undesignated statutory references are to the Welfare and Institutions Code. 2 Petitioner is in the custody of the Department of Corrections and Rehabilitation and mailed his documents to the superior court from Corcoran State Prison.

2. pertaining to presence at hearings and not access to the case file, petitioner’s petition was overbroad, and the order denying the petition was without prejudice to petitioner’s submission of a more narrowly tailored petition. Petitioner filed a Judicial Council form JV-180 (Request to Change Court Order) on August 6, 2025, and requested modification of the court’s June 30, 2025 order. Petitioner alleged that the request was pursuant to section 385, which permits a court to reconsider previous orders despite the absence of a section 388 petition establishing changed circumstances. Petitioner argued that the request was not overbroad because other relatives, including S.B.’s aunt and grandmother, “have had access to all of the information requested” because “they have been allowed access to the proceedings from the start.” Petitioner also argued that the court’s order denied him equal protection under the law because other relatives had attended the hearings. Additionally, petitioner argued that maintaining a relationship with him was in S.B.’s best interests and he had valuable insight into the parties involved in S.B.’s case. The juvenile court denied the request on August 8, 2025, because it did not state new evidence or a change in circumstance, did not promote the best interests of the child, and appeared unrelated to the order which petitioner sought to change. Petitioner filed this timely appeal on September 23, 2025. DISCUSSION Petitioner raises four issues in this appeal: (1) he was denied access to the proceedings; (2) other relatives were granted access to the proceedings or visitation; (3) his right to equal protection under the law has been violated; and (4) the juvenile court misapplied the law in denying his request to change the court’s order denying him access to the juvenile court records. Of these four issues, only the last is properly raised in petitioner’s appeal, an appeal from the court’s denial of petitioner’s request to change the court’s order, and we affirm.

3. I. The juvenile court did not abuse its discretion by denying access to juvenile court records. A. Sections 827, 385, 388 and the Standard of Review on Appeal The Legislature has expressly stated that “juvenile court records, in general, should be confidential.” (§ 827, subd. (b)(1).) “Thus, section 827 restricts access to the case file in a juvenile proceeding. That section lists persons entitled to inspect the file without a court order, and a smaller number of persons who are also entitled to receive copies of the file without a court order. (§ 827, subd. (a)(1), (5); [Cal. Rules of Court,] rule 5.552(b)(1).)” (In re B.F. (2010) 190 Cal.App.4th 811, 818.) Although anyone may petition the juvenile court to inspect or copy the case file, grandparents are not included as persons who are entitled to do so without a court order. (§ 827, subd. (a)(1); Cal. Rules of Court,3 rule 5.552(b)(3), (c).) Section 827, however, permits disclosure of juvenile court records to certain persons, including any “person who may be designated by court order of the judge of the juvenile court upon filing a petition.” (§ 827, subd. (a)(1)(Q); see In re B.F., at p. 818.) The petitioner must identify the “specific file sought” and “describe in detail the reasons the file is being sought and its relevance to the proceeding or other purpose for which petitioner wishes to inspect or obtain the files.” (Rule 5.552(a)(1), (2).) The petitioner seeking access to the records bears the burden to show good cause justifying such access. (Rule 5.552(c)(1), (2).) The petitioner has the burden of proving by a preponderance of the evidence that “the records requested are necessary and have substantial relevance to the legitimate need of the petitioner.” (Rule 5.552(c)(6).) “[I]f the court determines that there may be information or documents in the records sought to which the petitioner may be entitled, the juvenile court judicial officer must conduct an in camera review of the juvenile … case file and any objections and assume that all legal claims of privilege are asserted.” (Rule 5.552(c)(3).)

3 Undesignated rule references are to the California Rules of Court.

4. To determine whether to grant the petition, the court “must balance the interests of the child and other parties to the juvenile court proceedings, the interests of the petitioner, and the interests of the public.” (Rule 5.552(c)(4).) “[T]he court must find that the need for access outweighs the policy considerations favoring confidentiality of the juvenile … case file” to grant the petition.

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