In In re Tamika T. (2002) 97 Cal.App.4th 1114, the court addressed the question whether a parent "has a due process right to a contested hearing on the applicability of a section 366.26 exception." (At p. 1120.) The court noted that "'a parent has a right to "due process" at the hearing under section 366.26 which results in the actual termination of parental rights.'" (Ibid.) But "'due process is a flexible concept which depends upon the circumstances and a balancing of various factors.'" (Ibid., ) Among the factors to be considered are the parent's right to present "'relevant evidence of significant probative value to the issue before the court'" and the "'state's strong interest in prompt and efficient trials.'" (Id. at p. 1122.) The court concluded that at a section 366.26 hearing, the juvenile court "can require an offer of proof to insure that before limited judicial and attorney resources are committed to a hearing on the issue, the parent has evidence of significant probative value. . . . Due process does not require a court to hold a contested hearing if it is not convinced the parent will present relevant evidence on the issue he or she seeks to contest. The trial court can therefore exercise its power to request an offer of proof to clearly identify the contested issue(s) so it can determine whether a parent's representation is sufficient to warrant a hearing involving presentation of evidence and confrontation and cross-examination of witnesses." (In re Tamika T., supra, 97 Cal.App.4th at p. 1122.) In In re Tamika T. (2002) the mother at the section 366.26 hearing on terminating her parental rights argued that a statutory exception applied. (Tamika, supra, 97 Cal.App.4th at p. 1116.) The court required an offer of proof from her on that issue and ruled that her offer was insufficient to warrant a contested hearing. After making the appropriate findings, the court terminated her parental rights. (Ibid.) The mother contended that her due process rights were violated under subdivisions (b) and (c)(1) of section 366.26. The reviewing court explained that it is well settled that due process is a flexible concept in a dependency proceeding. (Tamika, supra, at p. 1123.) Therefore, the lower court can request an offer of proof to identify the contested issues "so it can determine whether a parent's representation is sufficient to warrant a hearing involving presentation of evidence and confrontation and cross-examination of witnesses." (Id. at p. 1122.)