RulesofCivilProcedure.com Civil Procedure · Every State

Rule 5.661.Representation of the child on appeal

Division 3. Juvenile Rules · Chapter 11. Advocates for Parties · Last amended 2015 · Last verified September 10, 2026

In one sentenceRule 5.661 governs representation of the child on appeal, including when trial counsel should recommend that the Court of Appeal appoint separate appellate counsel.

Full Text of Rule 5.661

Text sizeJump to: (a) (b) (c) (d) (e) (f) (g)

(a) Definition
For purposes of this rule, “guardian ad litem” means a person designated as the child’s Child Abuse Prevention and Treatment Act (CAPTA) guardian ad litem as defined in rule 5.662.
(b) Child as appellant
A notice of appeal on behalf of the child must be filed by the child’s trial counsel, guardian ad litem, or the child if the child is seeking appellate relief from the trial court’s judgment or order.
(c) Recommendation from child’s trial counsel or guardian ad litem
(1) In any juvenile dependency proceeding in which a party other than the child files a notice of appeal, if the child’s trial counsel or guardian ad litem concludes that, for purposes of the appeal, the child’s best interests cannot be protected without the appointment of separate counsel on appeal, the child’s trial counsel or guardian ad litem must file a recommendation in the Court of Appeal requesting appointment of separate counsel.
(2) A child’s trial counsel or guardian ad litem who recommends appointment of appellate counsel for a child who is not an appellant must follow the procedures outlined in (d)–(g).
(d) Time for trial counsel or guardian ad litem to file the recommendation with
the Court of Appeal
A recommendation from the child’s trial counsel or guardian ad litem may be filed at any time after a notice of appeal has been filed, but absent good cause, must be filed in the Court of Appeal no later than 20 calendar days after the filing of the last appellant’s opening brief.
(e) Service of recommendation
The child’s trial counsel or guardian ad litem must serve a copy of the recommendation filed in the Court of Appeal on the district appellate project and the trial court.
(f) Factors to be considered
The following are factors to be considered by a child’s trial counsel or guardian ad litem in making a recommendation to the Court of Appeal:
(1) An actual or potential conflict exists between the interests of the child and the interests of any respondent;
(2) The child did not have an attorney serving as his or her guardian ad litem in the trial court;
(3) The child is of a sufficient age or development such that he or she is able to understand the nature of the proceedings; and
(A) The child expresses a desire to participate in the appeal; or
(B) The child’s wishes differ from his or her trial counsel’s position;
(4) The child took a legal position in the trial court adverse to that of one of his or her siblings, and an issue has been raised in an appellant’s opening brief regarding the siblings’ adverse positions;
(5) The appeal involves a legal issue regarding a determination of parentage, the child’s inheritance rights, educational rights, privileges identified in division 8 of the Evidence Code, consent to treatment, or tribal membership;
(6) Postjudgment evidence completely undermines the legal underpinnings of the juvenile court’s judgment under review, and all parties recognize this and express a willingness to stipulate to reversal of the juvenile court’s judgment;
(7) The child’s trial counsel or guardian ad litem, after reviewing the appellate briefs, believes that the legal arguments contained in the respondents’ briefs do not adequately represent or protect the best interests of the child; and
(8) The existence of any other factors relevant to the child’s best interests.
(g) Form of recommendation
The child’s trial counsel, the guardian ad litem, or the child may use Recommendation for Appointment of Appellate Attorney for Child (form JV-810). Any recommendation for an appellate attorney for the child must state a factual basis for the recommendation, include the information provided on form JV-810, and be signed under penalty of perjury.
End

Plain-English Summary

Where the child is the one seeking appellate relief, the notice of appeal is filed by the child’s trial counsel, the guardian ad litem, or the child.

The harder question is what happens when somebody else appeals. If the child’s trial counsel or guardian ad litem concludes that the child’s best interests cannot be protected on appeal without separate counsel, they must file a recommendation in the Court of Appeal asking for an appointment. It may be filed any time after the notice of appeal, but absent good cause no later than 20 calendar days after the last appellant’s opening brief. A copy goes to the district appellate project and the trial court.

The rule lists eight factors. An actual or potential conflict with a respondent’s interests. The child had no attorney serving as guardian ad litem below. The child is old or developed enough to understand the proceedings and either wants to take part in the appeal or holds a position different from trial counsel’s. The child took a position adverse to a sibling below and the briefs raise the issue. The appeal turns on parentage, inheritance rights, educational rights, evidentiary privileges, consent to treatment, or tribal membership. Postjudgment evidence has undermined the judgment entirely and every party is willing to stipulate to reversal. Trial counsel, having read the briefs, thinks the respondents’ arguments do not adequately protect the child’s interests. And any other factor relevant to those interests.

The recommendation may use form JV-810, and whatever form it takes it must state a factual basis, include the information the form calls for, and be signed under penalty of perjury.

Advisory Committee Comment

The following comment is published by the Judicial Council of California alongside the rule itself — not commentary from this site.

Generally, separate counsel for a nonappealing child will not be appointed for the purpose of introducing postjudgment evidence. See California Code Civ. Proc., § 909; In re Zeth S. (2003) 31 Cal.4th 396; In re Josiah Z. (2005) 36 Cal.4th 664. For further discussion, see In re Mary C. (1995) 41 Cal.App.4th 71.

Frequently Asked Questions

Who files a notice of appeal for the child?

The child’s trial counsel, the guardian ad litem, or the child, where the child is seeking appellate relief from the trial court’s judgment or order.

When should separate appellate counsel be recommended?

Where another party has appealed and the child’s trial counsel or guardian ad litem concludes the child’s best interests cannot be protected on appeal without separate counsel. The recommendation is filed in the Court of Appeal.

Is there a deadline?

The recommendation may be filed any time after a notice of appeal, but absent good cause must be filed no later than 20 calendar days after the last appellant’s opening brief.

What must the recommendation contain?

A factual basis for the recommendation and the information called for by form JV-810, signed under penalty of perjury. A copy is served on the district appellate project and the trial court.

Amendment History

Rule 5.661 amended effective January 1, 2015; adopted effective July 1, 2007.

(Subd (e) amended effective January 1, 2015.)

Source & verification. Rule text is reproduced verbatim from the Judicial Council of California. Adopted by the Judicial Council of California. Last verified September 10, 2026. · Official source
Also known as: appellate attorney for child dependencyform JV-810 recommendation appellate attorneyseparate appellate counsel juvenilechild appeal dependency California