Jensen D., Appellant v. State of Alaska, Department of Health & Social Services, Office of Children's Services…

Summary

The Alaska Supreme Court affirmed the superior court’s denial of the mother’s request to represent herself in a termination of parental‑rights proceeding. The Court held that the trial court did not abuse its discretion because the mother failed the “courtroom decorum” prong of the McCracken three‑factor test. The record showed her inability to stay focused and to refrain from interrupting witnesses, justifying the denial.