In Re the Welfare of Hall

This case presents the issue of whether and under what conditions appointed counsel in a child deprivation proceeding may withdraw from a frivolous appeal. We hold that, absent the client's consent, such withdrawal is never permitted and deny counsel's motion to withdraw in the present case. We also raise and consider two sub stantive issues sua sponte and, while not finding them frivolous, conclude there was no error in the present case.

The State instituted this action pursuant to RCW 13.34-.180 to terminate the parent-child relationship of appellant, Clayton Hall, and his wife, Debra Hall,…