Pacific Coast etc. Bank v. Clausen

In Pacific Coast etc. Bank v. Clausen (1937) 8 Cal.2d 364, the California Supreme Court refused to set aside a foreclosure judgment against a party who was a minor at the time she was served with the lawsuit and where no guardian ad litem was ever appointed for her. The court noted that the failure to appoint a guardian ad litem was not jurisdictional, "but merely irregular, and that where it did not appear that the minor's interests were substantially prejudiced thereby, there was no reversible error." ( Id. at p. 366.) In the case before it, the court held that any error in failing to require the appointment of a guardian ad litem "was not prejudicial to any substantial right of the appellant, and hence did not constitute reversible error." (Ibid.)