Stanislaus County Community Services Agency v. Mirna C.

Mirna C. appeals from an order terminating her parental rights (Welf. & Inst. Code, § 366.26) to her daughter, Angela. 1 She contends she received inadequate notice of the termination hearing and thus is entitled to per se reversal. On review, we find appellant received no notice of a continuance of the termination hearing. We hold the error, albeit a due process violation under In re Phillip F. (2000) 78 Cal.App.4th 250, 258-259 [ 92 Cal.Rptr.2d 693 ], is subject to the Chapman prejudice standard of harmless beyond a reasonable doubt. 2 Having reviewed the record under this standard, we conclude the error was harmless and we will affirm.

*392 Procedural and Factual History

Given the limited nature of this appeal, we need only briefly summarize the history of these proceedings. In March 2000, the Stanislaus County Superior Court adjudged Angela, bom in October 1999, a dependent child of the court and removed her from appellant’s custody. Appellant consented to dependency jurisdiction based on her physical abuse of Angela. After approximately 12 months of unsuccessful reunification efforts, the court terminated services and set a section 366.26 hearing for July 19, 2001,…