California, United States of America
The following excerpt is from Johnson v. Superior Court of Kern County, 107 Cal.Rptr. 83, 31 Cal.App.3d 143 (Cal. App. 1973):
In Briggs v. Briggs (1958) 160 Cal.App.2d 312, at page 319, 325 P.2d 219, at page 223, the court said:
'Improper failure to appoint a guardian ad litem does not affect the jurisdiction of the court that proceeded without
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