## Facts

- A juvenile dependency proceeding concerned a child, M.F., whose mother, C.F., was herself a minor during the case.
- The juvenile court ultimately terminated C.F.’s parental rights.
- C.F. appealed, arguing the juvenile court should have appointed her a guardian ad litem earlier in the dependency case because she was a minor parent.
- The appeal focused on whether the timing of guardian ad litem appointment affected the validity of later dependency and termination proceedings.

## Issues

1. Whether a juvenile court commits reversible error by failing to appoint a guardian ad litem early in a dependency case for a parent who is a minor.
2. Whether such a failure requires reversal of an order terminating parental rights.

## Decision

- The Court of Appeal reviewed the termination order in light of the claim that the juvenile court delayed appointing a guardian ad litem for the minor parent.
- The court treated the dispute as turning on whether the alleged appointment error undermined the fairness and validity of the proceedings leading to termination.

## Legal Principles

- In dependency proceedings, a parent who is a minor may require a guardian ad litem to protect the parent’s interests and ability to participate meaningfully.
- A challenge to termination based on procedural error requires showing the error was material to the proceedings and affected the outcome, not merely that an appointment should have occurred earlier.
- Appellate review of termination orders considers whether claimed procedural defects warrant reversal under applicable prejudice standards.

## Conclusion

The appellate court evaluated whether the juvenile court’s timing in appointing a guardian ad litem for a minor parent constituted reversible error impacting the termination of parental rights, framing the inquiry around the need for meaningful protection of the minor parent’s participation and any resulting prejudice.


In re M.F., 161 Cal. App. 4th 673 (Cal. Ct. App. 2008)