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In re JAMES W.
Where juvenile court appointed guardian ad litem for parent in dependency proceedings and subsequently terminated parental rights, its failure to explain guardian ad litem to parent and to give parent meaningful opportunity to be heard in opposition to appointment was error, but was subject to harmless error analysis rather than automatic reversal because of differences between dependency and criminal proceedings. Parent suffered no prejudice from error where evidence pointed to conclusion that he was mentally incompetent and in need of guardian ad litem, and would have consented to appointment had it been properly explained. Juvenile court's error was not a structural defect that precluded harmless error analysis because no evidence suggested that error stripped parent of his right to participate in action, that ruling was necessary to enhance incentive to avoid similar error, or that error had undermined integrity and fundamental fairness of dependency proceedings.

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