The Second Appellate District affirmed an order of the dependency court. The court held that in rejecting the collateral attack, by a parent whose parental rights were terminated, on case orders made before his first appearance, any due process violations were harmless beyond a reasonable doubt.
The Los Angeles County Department of Children and Family Services (county) detained J.H., then twenty months old, in March 2004 after P.H. (Mother) was arrested and then incarcerated for burglary. When J.H. was detained, Jorge R. (Father) was incarcerated and had not had any contact with his daughter J.H. for four months.
