Care & Protection of Marina

Although the petitioner and his counsel participated in the initial stage of the underlying care and protection proceeding, the petitioner has apparently not participated in any of the numerous later sessions, including those pertaining to the subsequent request of the Department of Social Services (department) to dispense with parental consent to adoption. Counsel for the petitioner now protests that petitioner’s nonaction is not a voluntary, knowing, and intelligent waiver of his right to counsel. We need not. reach the question whether that is the appropriate standard in these…