California, United States of America
The following excerpt is from San Bernardino Cnty. Children & Family Servs. v. D.C. (In re G.L.), E055736 (Cal. App. 2012):
would have been the same under any standard, even under a federal constitutional standard. The lack of changed circumstances (as opposed to changing circumstances) and the absence of any showing how the proposed change would benefit the minor render any error harmless beyond a reasonable doubt. (Chapman v. California (1967) 386 U.S. 18, 24 [87 S.Ct. 824, 17 L.Ed.2d 705]. We do not need to remand the matter to the juvenile court for a new hearing because even under the preponderance of evidence burden of proof, mother's petition would have been denied.
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