Jennifer B. v. Dan H.

A state family court entered an emergency order in petitioner’s absence after approximately 49 minutes’ email notice. The order eliminated all parent-child contact and remained in effect until a merits trial approximately eight months later. The state appellate court held that the later final order superseded the emergency order, leaving the completed interim constitutional deprivation without effective appellate relief. Whether the Fourteenth Amendment’s Due Process Clause permits an emergency order eliminating all parent-child contact to remain in effect for approximately eight months without a prompt adversarial hearing, and whether a later merits hearing automatically cures or moots the completed interim deprivation.