A mother whose parental rights were terminated but who retained visitation rights does not have standing in a dependency hearing despite the fact that the court had placed conditions on the mother regarding her substance abuse, a Pennsylvania Superior Court panel ruled last week.

In pointing to the three classes of people the courts have historically recognized as having standing in these matters, President Judge Kate Ford Elliott said biological mother S.M. did not fall into any of those categories even if she were a potential placement resource for her son and even if the court had put restrictions on her behavior in response to her care of her son, D.M.

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