CALIFORNIA FAMILY LAW
...Procedure After Trial/Hearing
......Attack on Judgments/Orders
.........Void Judgments/Orders/Defaults
............Constitutional Defect
4 Cards On This Topic:

Judgment entered in violation of party's constitutional right to counsel is voidable upon specified showing.

To void stipulated paternity/support judgment entered without attorney, D must show both agreement involuntary and diligence in trying to set aside.

Soto retroactive. Paternity judgment reversed to permit D who had been unrepresented when signed stipulation to satisfy Soto test.

Judgment entered in violation of party's constitutional right to counsel is subject to attack.