In re Christopher L.

Opinion of the Court by Liu, J.

Justice Liu authored the opinion of the Court, in which Chief Justice Cantil-Sakauye and Justices Corrigan, Kruger, Groban, Jenkins, and Peña* concurred.

* Associate Justice of the Court of Appeal, Fifth Appellate District, assigned by the Chief Justice pursuant to article VI, section 6 of the California Constitution. In re CHRISTOPHER L.

S265910

Opinion of the Court by Liu, J.

California law requires the appointment of counsel for parents whose children are subject to dependency proceedings before the juvenile court. When such parents are incarcerated, the law specifically provides for notice and the opportunity to be present, and prohibits a juvenile court from adjudicating a dependency petition without the presence of both counsel and the incarcerated parent except upon affirmative waiver by the parent. These requirements, among others, protect the parent’s interest in maintaining the parent-child relationship and the child’s interest in having a dependency petition decided on the basis of all factors that bear on the child’s well-being. Here we decide whether it is structural error, and thus reversible per se, for a juvenile court to…