In re K.M.W.
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The Supreme Court reversed the orders of the trial court terminating Mother's parental rights in her two children, holding that, given the very limited inquiry inquiry that the trial court undertook before allowing Mother's counsel's withdrawal motion, the trial court erred by allowing that motion.
During the termination proceedings, Mother retained Roy Dawson to represent her. Dawson later filed motions seeking leave to withdraw as Mother's counsel in the proceedings. The trial court granted the request without further inquiry. After a termination of parental rights hearing, Mother's parental rights were terminated. Mother appealed, arguing that the trial court failed to make a proper inquiry before allowing Dawson's withdrawal motion. The Supreme Court agreed and reversed, holding that the trial court erred by allowing Mother's counsel to withdraw his representation of Mother without (1) making an adequate inquiry into the circumstances surrounding the making of that motion; and (2) inquiring, at the time Mother appeared at the termination hearing, whether she was represented by counsel, whether she wished to apply for court-appointed counsel, or whether she wished to represent herself.
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