In re Taijha H.-B.

Summary

The separate opinion agrees with the majority except on whether due process requires Anders-like procedures when appointed counsel seeks to withdraw from an appeal following termination of parental rights. It would hold that the balancing of the private, governmental, and error-related interests does not overcome the presumption against a constitutional right to appointed counsel absent a risk of physical liberty deprivation, particularly because the child's interests may diverge from the parent's. Accordingly, it would rely on Connecticut's statutory and procedural protections rather than require Anders procedures.