In re S.W.
J.F. (Mother) appeals from the juvenile courts order terminating her parental rights to her daughter, S.W., pursuant to Welfare and Institutions Code section 366.26 (all further code references are to the Welfare and Institutions Code unless otherwise indicated). Mothers trial attorney had signed a stipulation to terminate parental rights, and the juvenile court found a factual basis for the stipulation based on reports submitted by the Orange County Social Services Agency (SSA).
Court affirm without deciding whether the juvenile court had an obligation to determine whether Mother knowingly, voluntarily, and intelligently stipulated to terminating her parental rights. We conclude (1) any error in failing to make those determinations, if of constitutional magnitude, was not structural, but is subject to a harmless error analysis; and (2) any error was harmless beyond a reasonable doubt under the Chapmanv.California (1967) 386 U.S. 18 standard. Court therefore affirm.
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