Can a judge order that a defendant be denied counsel at the Juvenile Court of Appeal?

The presence of counsel may have protected appellant from the consideration of biased and untrustworthy evidence. ⁴ Counsel would have served the important role of preserving the record for appeal. Counsel, in effect, would have served the vital role of protecting appellant's rights in an adversarial proceeding. "When a defendant has been denied any essential element of a [50 Cal.App.4th 1438] fair trial or due process ... the judgment cannot stand. [Citations.]" (People v. Sarazzawski (1945) 27 Cal.2d 7, 11, 161 P.2d 934.) The right to counsel is a fundamental due process guarantee and we therefore must reverse the order of the juvenile court dated September 29, 1992, vacating its judgment even if we assume that court had jurisdiction to consider and issue such an order. (Gideon v. Wainwright (1963) 372 U.S. 335, 83 S.Ct. 792, 9 L.Ed.2d 799; Mempa v. Rhay, supra, 389 U.S. 128, 88 S.Ct. 254, 19 L.Ed.2d 336.)