In re Christopher L.
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The Supreme Court affirmed the judgment of the juvenile court, holding that the juvenile court committed serious errors by proceeding with a hearing to determine its jurisdiction over a child and disposition of a wardship petition without an incarcerated parent's presence and without appointing counsel for the parent, but the rule of automatic reversal was unwarranted in this case.
The Los Angeles Department of Children and Family Services filed a dependency petition alleging that two children were at risk due to Mother's ongoing substance abuse and Father's criminal history. Neither Father, who was incarcerated, nor counsel for Father appeared at the ensuing combined jurisdiction and disposition hearing. The court sustained the petition as to both Father and Mother. Thereafter, the court terminated Father's parental rights. The court of appeal affirmed. The Supreme Court affirmed, holding that it was not structural error for the juvenile court to proceed with the jurisdiction and disposition hearing without Father's presence and without appointing Father an attorney.
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