In re Baby Girl Baxter

This case raises three issues. The first is whether Evelyn Baxter was denied the proper representation of counsel during the proceedings in Carroll County Juvenile Court.

R.C. 2151.352 and Juv. R. 4(A) provide for the appointment of counsel in cases where parental rights are subject to termination. Furthermore, this court has held that the state must appoint counsel for indigent parents at parental termination proceedings. State, ex rel. Heller, v. Miller (1980), 61 Ohio St. 2d 6 [15 O.O.3d 3]. Juv. R. 4(B)(3) and R.C. 2151.281 mandate that the court appoint a guardian ad litem to protect the…