In re Z.O.
The court held that a juvenile dependency court's failure to make the statutorily required findings before appointing a guardian ad litem for a parent constitutes a reversible-not harmless-error, so although it conditionally affirmed the termination of parental rights, it remanded for the trial court to make explicit findings on the necessity of the GAL and to supplement the Indian Child Welfare Act investigation, thereby underscoring that termination proceedings.
Date Filed: May 24, 2022
Case Name: In re Z.O.
Case Number: G060663
Court: California Supreme Court
The Fourth Appellate District holds that a juvenile dependency court’s appointment of a guardian ad litem for a parent without making the statutorily required findings is not a harmless error; the court therefore conditionally affirms the termination of parental rights but remands the case so the trial court must make explicit findings on whether a GAL was necessary at the time of appointment and supplement the ICWA investigation. This decision reinforces that termination proceedings must satisfy strict procedural safeguards—including documented competence findings and compliance with the Indian Child Welfare Act—thereby shaping how probate and dependency courts handle parental‑rights terminations in California.
This case summary was prepared for educational purposes. For the authoritative version, please refer to the full opinion or the official California Courts website.