In re Taijha H.-B.

Summary

The court held that an indigent parent’s appeal from termination of parental rights could not be dismissed merely because appointed appellate counsel filed it before completing review of an incomplete transcript. It further held that, on the facts presented, due process required appointed appellate counsel and some procedure protecting against counsel’s mistaken conclusion that the appeal was frivolous before withdrawal was permitted. The court rejected the facial equal protection challenge because the rule’s references to a potentially meritorious appeal and a nonfrivolous appeal impose the same substantive standard.