In re Taijha H.-B.

Summary

The court reversed the dismissal of an indigent mother's amended appeal from the termination of her parental rights. It held that the appeal was not barred when appointed appellate counsel filed it before completing review because the record was incomplete, and that the mother had a fact-specific constitutional right to appellate counsel under due process. Because counsel could not withdraw merely by asserting that the appeal lacked a nonfrivolous issue, the trial court had to provide minimum Anders-type safeguards and independently determine whether the appeal was frivolous.