In In re James F. (2008) 42 Cal.4th 901, the California Supreme Court considered whether the juvenile court's error in the procedure used to appoint a guardian ad litem for the father constituted structural error, requiring automatic reversal of an order terminating the father's parental rights, or instead was trial error subject to harmless error review. (James F., supra, 42 Cal.4th at p. 910.) The juvenile court in that case failed to explain to the father the capacity and powers of a guardian ad litem and there was no dispute that the procedure employed for the appointment did not satisfy due process. Nevertheless, our Supreme Court concluded that "error in the procedure used to appoint a guardian ad litem for a parent in a dependency proceeding is trial error that is amenable to harmless error analysis" because, unlike structural error, prejudice could be determined without "'a speculative inquiry into what might have occurred in an alternate universe.' ." (Id. at p. 915.) Applying harmless error analysis, the James F. court found the result was indisputably correct because the record conclusively established the father "'was never ready to assume custody of his son due to his mental condition and his incarceration' and the father's brief and infrequent contacts with his son 'could not have created the type of bond and parent-child relationship necessary to force the child to forgo adoption.'" (Id. at p. 913.) While finding it appropriate to use the trial-versus-structural-error framework in James F., our Supreme Court noted significant differences between criminal and juvenile dependency proceedings that militate against importing the structural error doctrine "wholesale, or unthinkingly" into dependency cases. (See James F., supra, 42 Cal.4th at pp. 915-916.) The court observed that "in a criminal prosecution, the contested issues normally involve historical facts (what precisely occurred, and where and when), whereas in a dependency proceeding the issues normally involve evaluations of the parents' present willingness and ability to provide appropriate care for the child and the existence and suitability of alternative placements." (Id. at p. 915.) Additionally, the court noted, "the ultimate consideration in a dependency proceeding is the welfare of the child citation, a factor having no clear analogy in a criminal proceeding." (Ibid.) In view of these differences, the James F. court rejected that aspect of the structural error doctrine that categorizes certain constitutional errors as "structural, not because they defy harmless error analysis, but because prejudice is irrelevant and reversal deemed essential to vindicate the particular constitutional right at issue." (Id. at p. 917.)