M.A.W. v. the People in Interest of A.L.W

Summary

The court held that prejudice in an ineffective-assistance claim arising from a dependency and neglect proceeding is established only by a reasonable probability that counsel's errors affected the result, rather than by a general fundamental-fairness test. It also held that an appellate court may resolve such a claim without remanding for further fact-finding when the record is sufficiently developed or establishes presumptive prejudice. Applying those rules, the court concluded that the juvenile court did not abuse its discretion in rejecting the father's claims and affirmed termination of his parental rights.