In re Tommy E

In In re Tommy E. (1992) 7 Cal.App.4th 1234, a father submitted the issue of jurisdiction to the court for a decision based on a social worker's report. The Department contended that the submission amounted to a waiver of the father's right to contest the jurisdictional findings on appeal. The Court of Appeal held these facts did not effect a waiver of the right to contest the findings on appeal. (Id. at pp. 1237-1238.)