Mandatory Counsel for Children in Involuntary Termination of Parental Rights

The Supreme Court has held that 23 Pa.C.S. § 2313(a), which requires the appointment of counsel for children involved in contested involuntary termination of parental rights, is not satisfied by the appointment of a guardian ad litem who is also an attorney, because the guardian ad litem is required to consider the best interests of the children as well as the legal interests of the children.  In Re: Adoption of L.B.M., No 84 MAP 2016 (Pa. 3/28/2017), rev’g No. 1834 MDA 2015 (Pa. Super. 5/31/2016).

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