People in Interest of A.R

Summary

The court held that a parent generally may not raise ineffective-assistance claims concerning an earlier adjudicatory hearing for the first time in an appeal from a termination judgment when the parent had a full and fair opportunity to challenge the adjudication earlier. It adopted the reasonable-probability prejudice standard for ineffective-assistance claims in dependency and neglect proceedings and held that appellate courts may resolve such claims without a remand when the record is sufficiently developed or presumptive prejudice is established. Applying those rules, the court rejected the claims concerning the adjudicatory hearing and the offer of proof but held that counsel was ineffective in failing to litigate less drastic alternatives to termination, requiring further proceedings. No separate opinions were filed.