In Re AC

CORNELL, Acting P. J.—

Carl C. appeals from an order terminating his parental rights to his daughter, A.C. (Welf. & Inst. Code, § 366.26.) He contends the dependency court presiding over his child's dependency erred by not appointing a guardian ad litem on his behalf because he was a person for whom a conservator had been appointed (Code Civ. Proc., § 372, subd. (a)) (hereafter section 372). In separate proceedings, a superior court previously found Carl was gravely disabled (Welf. & Inst. Code, § 5008, subd. (h)) and consequently ordered and repeatedly renewed a conservatorship for him under the Lanterman-Petris-Short Act (LPS Act) (Welf. & Inst. Code, § 5000 et seq.). According to Carl, the dependency court's failure to comply with section 372 violated his due process rights and therefore is reviewable here and prejudicial under a harmless-beyond-a-reasonable-doubt standard.

We disagree and will affirm. We hold the dependency court's noncompliance with section 372 standing alone does not violate the parent's due process rights and the error is subject to a harmless error standard (Cal. Const., art. VI, § 13).

In January 2003, the Madera County Superior Court adjudged…