In Re Adoption of T.M.F.

The principal issue presented is whether a mother whose parental rights were involuntarily terminated was wrongfully denied the effective assistance of counsel at the termination proceeding.1 I agree with the majority that a decree terminating parental rights may not be disturbed on appeal on the. basis of a parent’s ineffectiveness of counsel claim unless the performance of counsel affected the outcome of the termination proceeding. I also agree that the appellant in this case has failed to prove that she was prejudiced by any error or omission on her counsel’s part. Accordingly, I concur in…