In re Z.K

In In re Z.K. (2011) 201 Cal.App.4th 51, the appellate court reversed an order terminating a mother's parental rights because the juvenile court failed to comply with basic statutory requirements designed to protect the mother's due process rights. (Id. at p. 72.) The appellate court concluded that, "under the circumstances of this case, ... where the juvenile court terminated mother's parental rights without making the requisite finding of detriment and without even understanding that such a finding was necessary--despite clear case law to the contrary," it was "in the interests of justice for a different judge to hear the proceeding on remand." (Ibid.)