In In re Robert S. (1979) 92 Cal.App.3d 355, the juvenile court considered previously sustained 602 petitions in fixing the juvenile's maximum period of physical confinement. On appeal, the court held that where multiple counts or petitions are aggregated, under section 726 the maximum term of physical confinement may be fixed by reference to "previously sustained 602 petitions." However, the court, referring to In re Aaron N. (1977) 70 Cal.App.3d 931, noted that if the maximum term of confinement is to be fixed on the basis of some prior criminal act for which a petition has been sustained, "the court must advise the minor of its intention to do so and afford the minor an opportunity to be heard prior to the commitment." ( Aaron N., supra, at pp. 939-941.) In Robert S, it was argued on appeal although the minor was not formally apprised of the court's intention to base any part of its commitment order on the earlier petition, he was put on notice by the court's reference to his most recent prior offense at the conclusion of the jurisdiction hearing. The court, however, held that "due process requires something more," and that the minor must be "given a meaningful opportunity to be heard regarding resort to past sustained petitions to increase the maximum permissible period of confinement." (Id. at p. 362.)