M.E.K. v. R.L.K.
Florida District Court of Appeal
921 So. 2d 787 (2006)
- Written by Deanna Curl, JD
Facts
In September 2004, M.E.K. (plaintiff) gave birth to J.L.K. The following month, the Department of Children and Family Services placed J.L.K. with his maternal grandmother, R.L.K. (defendant), and initiated dependency proceedings alleging that his mother was not able to care for him. The dependency court abated the proceedings before adjudication because the grandmother indicated that she intended to file a private adoption petition that would terminate parental rights. The grandmother subsequently filed a petition for termination of parental rights pending adoption in the trial court. The trial court defaulted the mother on the petition after she failed to appear because she was incarcerated. The mother’s attorney from the dependency case later filed a motion for court-appointed counsel in the adoption proceeding, and her appellate attorney filed a motion to appoint appellate counsel in an appeal of the termination order. After the trial court denied both motions for appointed counsel, the appellate court consolidated the mother’s appeals of the denial of appointed trial and appellate counsel.
Rule of Law
Issue
Holding and Reasoning (Pleus, C.J.)
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