A.W. v. Department of Children & Families

Affirmed. Competent substantial evidence supported the trial court’s determination that no fraud or duress was used to obtain the parents’ surrender of parental rights in order to allow for adoption. See K.C. v. Adoption Servs., Inc., 721 So.2d 811, 812 (Fla. 4th DCA 1998) (holding that the burden of proof is on the parent seeking to set aside consent to termination of parental rights, and evidence did not establish that the parent was under duress). Appellants were not entitled to appointed counsel for pursuing a post-judgment claim of ineffective assistance of counsel. See J.B. v. Fla.…