In re B.F

In In re B.F. (2010) 190 Cal.App.4th 811, a juvenile court abused its discretion by granting the de facto parents' request for access to the mother's court-ordered psychological evaluation because the court "elevated the de facto parents' interests to those of the parents, failed to consider the mother's interests and concluded without basis that the children's interests required disclosure of the psychological evaluation." (Id. at p. 820.) The B.F. court also concluded the de facto parents had no legitimate interest in seeing the evaluation because they did not need it "to provide care for the children. Insofar as the de facto parents were interested in adopting the children, that interest was not ripe for presentation to the court, as the case was still in the reunification phase." (Id. at p. 821.)