Apr. 25, 2022 – In re Christopher L. (Supreme Ct., S265910)

The issue before the Supreme Court was whether it was structural error for a juvenile court to proceed with a jurisdiction and disposition hearing without an incarcerated parent’s presence and without appointing the parent an attorney. The court holds that the prejudicial effects of such errors are not beyond the ability of courts to assess under a harmless error analysis. In the dependency context, automatic reversal for errors that do not invariably lead to fundamental unfairness would “exact a particularly steep cost” given the child’s critical interest in avoiding unnecessary delays to their long-term placement.