A newborn baby and its mother tested positive for controlled substances, and the mother soon thereafter violated the terms of a safety plan. The child was adjudicated dependant and remained in foster care. Later, the parties learned that the child’s purported biological father was not her father and instead the appellant was her father. After he learned of his child and the child’s dependency status, he claimed that his due process rights were violated because he was not notified of the initial dependency proceedings in this case and did not receive the opportunity to defend against the dependency allegations. The Pennsylvania Superior Court disagreed. It held that there was no error of law where no party knew that the appellant was the biological father. Thus at the time, no party had any reason to notify him of the proceedings.
