People Ex Rel. Ag

Summary

The court held that a parent cannot establish prejudice for an ineffective-assistance claim based solely on an alleged appearance of judicial impropriety; the parent must allege actual judicial bias or prejudice. Because the disqualification motion was filed after an adverse ruling despite long-standing knowledge of the asserted grounds, it was untimely and could not support a new hearing or further ineffective-assistance proceedings. The court left undisturbed the separate remand for additional findings concerning the statutory appropriateness of terminating parental rights.