Bechtel v. Rose

In Bechtel v. Rose, 150 Ariz. 68, 722 P.2d 236 (1986), the Arizona Department of Economic Security ("ADES") assumed care and custody of a child after the child's mother was killed in an auto accident. Bechtel, 150 Ariz. at 70, 722 P.2d at 238. ADES instituted a dependency proceeding, and a few weeks later the child's father formally relinquished his parental rights to the child. Id. As a result, there was no longer a parent involved and reunification with a parent was impossible. Id. The child's grandmother moved to intervene in the dependency proceeding, but the trial court summarily denied her motion to intervene. Id. The Arizona Supreme Courtfound that the trial court had abused its discretion and remanded, noting that "the tenor of Arizona's legislative and judicial decisions, as well as sound public policy," favors the important role of grandparents in maintaining the "integrity of the family." 150 Ariz. at 74-75, 722 P.2d at 242-43.