In re Dakota S

In In re Dakota S. (2000) 85 Cal.App.4th 494, the mother contended that the trial court's guardianship order had to be reversed because the Department of Health and Human Services failed to prepare a statutorily required preliminary assessment report. The appellate panel concluded "that the failure to provide the juvenile court with a preliminary assessment report is subject to the harmless error provision of our state Constitution (Cal. Const., art. VI, 13) when the court received, in other forms, the information that would have been contained in the preliminary assessment." (Id. at p. 503.)