R.A., In re (2021) A161510 A161510; filed 3/11/21. ![[Files/CaseFiles/A161510.PDF]] [Opinion PDF](https://www.courts.ca.gov/opinions/archive/A161510.PDF) ## Rule excerpts Welfare and Institutions Code section 388: remand for an evidentiary hearing on alleged failure of diligent notice. Whether the agency exercised due diligence remained to be determined (p. 14, fn. 12). Consolidated with A161529. > But, as we have seen, when a father shows he did not receive any notice of the dependency petition and the jurisdiction and disposition hearings due to the lack of diligence by the agency, a separate showing of best interest is not required. (Ansley, supra, 185 Cal.App.3d at p. 483; see DeJohn B., supra, 84 Cal.App.4th at pp. 109–110.) — R.A., In re (2021) A161510, slip op., p. 14.