What is the legal test for making an appearance by telephone rather than in person?
California, United States of America
The following excerpt is from Fields v. Ventura Cnty. Superior Court, 2d Civil No. B253852 (Cal. App. 2015):
Due process is flexible and calls for such procedural protections as the circumstances demand. (Gilbert v. City of Sunnyvale (2005) 130 Cal.App.4th 1264, 1276.) Under the circumstances here, where a party is unable to physically appear in court within a reasonable time, an appearance by telephone fully satisfies due process.
The judgment (order) is affirmed. Fields is to bear his own costs.
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