Sackman v. Seaburn

Summary

The Supreme Court of Delaware affirmed the Family Court’s award of guardianship to the child’s maternal aunt and its supervised-visitation order for the father. The Court held that the Family Court did not abuse its discretion by allowing appointed counsel to withdraw and declining to appoint replacement counsel after the father engaged in extremely serious, intimidating misconduct. The Court distinguished forfeiture from waiver and concluded that the Family Court’s factual findings supported forfeiture of any right to appointed counsel.