In re Louis F.
This proceeding was initiated by foster parents under Social Services Law section 392 to review the foster care status of the child Louis F., aiming to free him for adoption. Respondents, the Department of Social Services, Catholic Home Bureau, and the natural mother, sought to continue foster care, with the agency planning for the child's discharge to the natural mother. The foster parents moved for prehearing disclosure of various records related to the child and his natural parents, which the Family Court denied for lack of sufficient necessity. The Appellate Division affirmed this denial. The court reiterated that while foster parents, as parties in a foster care review, may obtain disclosure upon a proper showing of necessity coupled with in camera viewing by the Family Court, in this instance, after its own appellate in camera review, it found no abuse of discretion in the Family Court's decision.