Los Angeles County Department of Children & Family Services v. Jorge R.

Jorge R. (Father) appeals from an April 5, 2007 order terminating parental rights to his daughter, J.H., bom in July 2002. He contends that the juvenile court erred in rejecting his collateral attack on all case orders before his first appearance in the case on March 21, 2007, on the ground that he was denied his due process right to notice of those proceedings. We conclude that any due process violations were harmless beyond a reasonable doubt and affirm the April 5, 2007 order.

*177 BACKGROUND

The Los Angeles County Department of Children and Family Services (DCFS) detained J.H. in March 2004 after P.H. (Mother), who had a long history of drug abuse and a criminal record, was arrested and then incarcerated for burglary. When J.H. was detained, Father was incarcerated and had not had any contact with his daughter for over four months, but before that time, Father had provided milk, food, diapers, and whatever Mother needed for her. J.H. was initially detained in the home of her paternal aunt, but by May 2004, she was placed in foster care after DCFS learned that persons with a criminal record were residing in the aunt’s home. The paternal aunt also told a DCFS social…