In In re James F. (2008) 42 Cal.4th 901, the Supreme Court explained that the concept of structural error was developed in criminal cases: " "In Arizona v. Fulminante (1991) 499 U.S. 279, a criminal case in which the erroneous admission into evidence of a defendant's coerced confession was at issue, the United States Supreme Court distinguished constitutional errors called ' "trial errors" ' that 'occur during the presentation of the case to the jury' and the effect of which can 'be quantitatively assessed in the context of other evidence presented in order to determine whether they were harmless beyond a reasonable doubt' , from other, less common constitutional errors that are 'structural defects affecting the framework within which the trial proceeds' so that they 'defy analysis by "harmless-error" standards' and can never be harmless . Structural defects requiring automatic reversal of a criminal conviction typically involve basic protections without which ' "a criminal trial cannot reliably serve its function as a vehicle for determination of guilt or innocence, and no criminal punishment may be regarded as fundamentally fair." ' These include total deprivation of the right to counsel, denial of the right of self-representation, trial before a judge who is not impartial, unlawful exclusion of members of the defendant's race from a grand jury, and denial of the right to a public trial. Admission of an involuntary confession by the defendant, the high court concluded, was a trial error subject to harmless error analysis. " (Id. at p. 914.) The James F. court pointed out significant differences between juvenile dependency proceedings and criminal proceedings. "In a criminal prosecution, the contested issues normally involve historical facts (what precisely occurred, and where and when), whereas in a dependency proceeding the issues normally involve evaluations of the parents' present willingness and ability to provide appropriate care for the child and the existence and suitability of alternative placements. Finally, the ultimate consideration in a dependency proceeding is the welfare of the child , a factor having no clear analogy in a criminal proceeding." (In re James F., supra, 42 Cal.4th at p. 915, italics omitted.) The issue in James F. was whether the juvenile court's error in the procedure used to appoint a guardian ad litem for the father in a dependency proceeding required automatic reversal of an order terminating the father's parental rights or whether instead the error was subject to harmless error review. The juvenile court failed to explain to the father the capacity and powers of a guardian ad litem nor did it provide the father a meaningful opportunity to voice opposition to the appointment. There was no dispute that the process by which the guardian ad litem was appointed did not satisfy due process. Nevertheless, the court found that the juvenile court's due process error was not structural. The court noted that the result achieved in the case was correct and fair because the father was never ready to assume custody of his son. It found it appropriate to use a harmless error analysis because, unlike structural error, prejudice could be determined without " 'a speculative inquiry into what might have occurred in an alternate universe.' " (In re James F., supra, 42 Cal.4th at p. 915.) The court concluded: "If the outcome of a proceeding has not been affected, denial of a right to notice and a hearing may be deemed harmless and reversal is not required. " (Id. at p. 918.)