B. Dependency

The Supreme Court has not recognized a right of access to juvenile dependency proceedings or records, and in “abuse, neglect, dependency, and custody matters…courts have hesitated to extend a First-Amendment-based right of access.” Dienes, Levine & Lind, Newsgathering and the Law § 7.01[2] (3d Ed. 2005) (collecting cases). In the absence of a presumption of openness, access varies widely from jurisdiction to jurisdiction.