In In re J.H. (2007) 158 Cal.App.4th 174, the court was presented with a situation where a father made an attack on the orders that preceded his first appearance in the case. The father was incarcerated when the minor was detained. He was released from jail by the time the adjudication and disposition hearing was held but the court found there was no due diligence search for him for that hearing. Notice of subsequent hearings was also wanting. However, the court found that even if the Department did not comply with due process notice requirements, the errors were harmless because the father's assertions of how he would have seen to the child's care and maintained his parental rights did not ring true. The relative placement he would have asserted for the minor would not have materialized and he had a transient life style. Further, the father "knew about the dependency proceedings at some point and chose not to contact the Department." The court found that actual notice would not have changed the outcome of the jurisdiction and disposition hearing.