In Re MF

CANTIL-SAKAUYE, J.

C.F., the mother of the infant and a minor herself, appeals from the juvenile court's order terminating parental rights. (Welf. & Inst.Code, §§ 366.26, 395.) [1] She contends the juvenile court erred by failing to appoint her a guardian ad litem until after her reunification services were terminated and the hearing to terminate her parental rights was pending. As C.F. was a minor throughout these proceedings, we agree she was entitled to the protections of a guardian ad litem. We cannot find the error harmless in this case and, accordingly, shall reverse the order terminating parental rights.

In October 2005, when C.F. was 14 years old, the San Joaquin County Human Services Agency (the Agency) filed a dependency petition concerning the 10-month-old infant, alleging that C.F. had been subjected to ongoing sexual abuse by her stepfather over a four-year period, resulting in the birth of the infant. Although C.F.'s mother knew about the sexual abuse, she told C.F. to lie about it to law enforcement personnel when the allegations were first investigated.

The juvenile court sustained the allegations in the petition pursuant to C.F.'s no contest plea and ordered…