In In re Jasmine G. (2005) 127 Cal.App.4th 1109, a social services agency made absolutely no effort to locate and serve notice on a parent for approximately five months prior to a Welfare and Institutions Code section 366.26 permanency planning hearing, even though it had eight telephone contacts and one meeting with the parent during that time period and had obtained the parent's current residence. (Jasmine G., supra, 127 Cal.App.4th at pp. 1113-1114 & 1116.) The appellate court held the failure to comply with the notice requirements constituted a due process violation, which was structural in nature requiring automatic reversal, rather than trial error subject to harmless error analysis. (Id. at pp. 1114-1116.) The court began by discussing Arizona v. Fulminante (1991) 499 U.S. 279, a criminal case, which explained that all constitutional errors are not equal. (Jasmine G., supra, 127 Cal.App.4th at p. 1115.) In Fulminante, the United States Supreme Court distinguished trial errors, which may be evaluated to see if the error was harmless beyond a reasonable doubt, from structural errors, which defy analysis by a harmless-error standard and demand automatic reversal. (Jasmine G., supra, 127 Cal.App.4th at p. 1116, citing Fulminante, supra, 499 U.S. at pp. 307-309.) tructural defects are those "affecting the framework within which the trial proceeds, rather than simply an error in the trial process itself. 'Without these basic protections, 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.'" (Fulminante, supra, 499 U.S. at p. 310.) The Jasmine G. court observed that California courts have applied Fulminante outside the criminal context, including notice failings in juvenile dependency proceedings, although the courts were divided on whether such due process errors were structural in nature. (Jasmine G., supra, 127 Cal.App.4th at p. 1115.) Notably, one of the California decisions cited was In re Angela C. (2002) 99 Cal.App.4th 389 (Angela C.), an opinion from the Court, which came down on the side of trial, rather than structural, error. The court in Jasmine G., however, distinguished Angela C., as there the error was the social services agency's failure to give the parent, who failed to appear at the selection and implementation hearing despite being given proper notice, notice of a continued hearing date, while the failure in Jasmine G. was "qualitatively different," as the social services agency never tried to give the parent notice of the hearing, despite having been in regular contact with her and having a current address. (Jasmine G., supra, 127 Cal.App.4th at pp. 1117-1118.) The appellate court held the failure to attempt to give a parent statutorily required notice of a selection and implementation hearing is a structural defect that requires automatic reversal, reasoning that the absence of any reasonable attempt to provide such notice goes well beyond trial error. (Id. at p. 1116.)