Legal Opinion

In re the Dependency of E.P.

Court of Appeals of Washington

Decided December 21, 2006No. 24098-3-IIIPublishedCited by 9 opinions

1Opinion of the Court

¶1 By statute derived from due process guaranties, indigent parents have the right to counsel in termination proceedings. RCW 13.34.090(2); In re Welfare of J.M., 130 Wn. App. 912, 921, 125 P.3d 245 (2005). That right, however, may be forfeited. In re Welfare of G.E., 116 Wn. App. 326, 334, 65 P.3d 1219 (2003). In the circumstances here, R.P. forfeited her right to counsel. We accordingly affirm the termination of her parental rights.

Kato, J.

¶2 While incarcerated, Ms. P. gave birth to E.P. on July 12, 2004. The Department of Social and Health Services (DSHS) filed a dependency action. On July…

2Cases cited8 opinions

  1. United States v. Ronald J. GoldbergCourt of Appeals for the Third Circuit · 1995
  2. McCarthy v. SchuolerWashington Supreme Court · 1986
  3. In Re Welfare of JMCourt of Appeals of Washington · 2005
  4. In re the Welfare of J.M.Court of Appeals of Washington · 2005
  5. City of Tacoma v. BishopCourt of Appeals of Washington · 1996

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3Cited by9 opinions

  1. City of Seattle v. KleinWashington Supreme Court · 2007
  2. City of Seattle v. KleinWashington Supreme Court · 2007
  3. In re the Welfare of S.I.Court of Appeals of Washington · 2014
  4. E.P. v. Etowah County Department of Human ResourcesCourt of Civil Appeals of Alabama · 2010
  5. In re the Parental Rights to M. I-S.Court of Appeals of Washington · 2016

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