In re James F.
Marcus M. appealed from the juvenile courts order terminating parental rights to his son, James F., alleging error in appointing a guardian ad litem without inquiring about his competence and in failing to obtain a knowing waiver of his right to be present at the termination of parental rights hearing. This court previously concluded that the juvenile courts error in appointing a guardian ad litem without inquiring into Marcus M.s competence constituted a structural error requiring the reversal of the orders terminating his parental rights. On review, the California Supreme Court concluded that the error in the guardian ad litem appointment process was subject to harmless error analysis and was in fact harmless. (In re James F. (2008) 42 Cal.4th 901.) On remand, Court consider the question of whether the failure to obtain a knowing waiver of Marcus M.s right to be present at the hearing at which parental rights were terminated requires reversal. Court conclude that this, too, was harmless error, and affirm the judgment of the juvenile court.
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