In Re James Q.

[EDITORS' NOTE: THIS PAGE CONTAINS HEADNOTES. HEADNOTES ARE NOT AN OFFICIAL PRODUCT OF THE COURT, THEREFORE THEY ARE NOT DISPLAYED.] *Page 257 Recently this court decided it is an abuse of discretion for the juvenile court to deny a parent a contested review hearing (Welf. Inst. Code, § 366.21 , subd. (e)) 1 when the parent has tendered an adequate statement explaining the basis of her request for a contested hearing. ( Ingrid E . v. Superior Court (1999) 75 Cal.App.4th 751 .) Left unresolved in that case was the general issue whether a juvenile court has the power to require a formal offer of proof before a party may obtain a contested review hearing. The matter before us presents that issue. We conclude the court may not, consistent with the requirements of statute and principles of due process, deny a party the right to a contested review hearing based on an allegedly inadequate or even a nonexistent offer of proof. BACKGROUND On September 21, 1998, the Department of Health and Human Services (DHHS) filed amended section 300 petitions on behalf of three-year-old James and four-year-old Matthew. Those petitions alleged generally that appellant, Kathleen K., the mother of the…