In re Christopher L.

Summary

The court held that a juvenile court's failure to appoint counsel for an incarcerated presumed father and provide for his presence at a combined jurisdiction and disposition hearing is serious error but not structural error requiring automatic reversal. Because the potential prejudice can be assessed without necessarily resorting to speculation, the error is amenable to harmless-error review, although the court did not decide which harmless-error standard applies or whether the error was harmless here. The court affirmed the Court of Appeal's judgment.