Legal Opinion

M.D. v. Department of Children & Family Services

District Court of Appeal of Florida

Decided April 15, 2009No. 2D08-2661PublishedCited by 2 opinions

1Opinion of the Court

LaROSE, Judge.

M.D., the mother, appeals an order terminating her parental rights. The Department of Children and Family Services and the Guardian Ad Litem Program concede error. We reverse because the trial court failed to (1) appoint counsel for an extended period of time when termination was at issue and (2) advise M.D. of her right to counsel or to obtain a record waiver of counsel. See, e.g., J.C.-J. v. Dep’t of Children & Family Servs., 987 So.2d 828, 829 (Fla. 2d DCA 2008) (discussing • due process right to counsel at all appropriate stages in termination of parental rights proceedings…

2Cases cited5 opinions

  1. T.H. v. Department of Children & Family ServicesDistrict Court of Appeal of Florida · 2008
  2. In the Interest of L.N. v. Department of Children & Family ServicesDistrict Court of Appeal of Florida · 2002
  3. S.H. v. Department of Health & Rehabilitative ServicesDistrict Court of Appeal of Florida · 1994
  4. Beveridge v. MardisDistrict Court of Appeal of Florida · 1996
  5. J.C.-J. v. Department of Children & Family ServicesDistrict Court of Appeal of Florida · 2008

3Cited by2 opinions

  1. In Re CsDistrict Court of Appeal of Florida · 2009
  2. MT v. Department of Children and FamiliesDistrict Court of Appeal of Florida · 2009

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