Smith v. Organization of Foster Families for Equality and Reform (Offer)

New York (defendant) allowed a foster-care agency to remove a child from a foster home upon at least ten days' notice, with the foster parents entitled to a preremoval conference, a post-removal adversarial hearing with judicial review after 18 months' placement, and (in New York City) an additional independent review option; foster parents and OFFER (plaintiffs) sued alleging these procedures violated their due process and equal protection rights, and natural parents intervened to defend their own right to regain custody.