In re Megan B

In In re Megan B. (1991) 235 Cal. App. 3d 942, at the jurisdictional hearing the mother entered a plea of nolo contendere. ( Id., at p. 947.) After further hearings, the court authorized a proceeding to terminate her parental rights under former Civil Code section 232. ( In re Megan B., supra, at pp. 947-949.) In her appeal, the mother argued, among other things, that her nolo plea was invalid because the juvenile court made no finding that her waiver of her rights was knowing and voluntary, "and the invalid jurisdictional finding based on it voided any orders thereafter entered by the court." ( Id., at p. 949.) The appellate court held: "Her assault on the validity of the jurisdictional finding comes too late." ( Id., at p. 950.) "A jurisdictional finding, while not appealable, may be reviewed in an appeal from the dispositional order. " (Ibid.) "Here, Annette did not appeal from the dispositional order and the time for doing so has long since expired." (Ibid.)