New York Court of Appeals
In the Matter of Kathleen K., a Child Alleged to Be Permanently Neglected. Suffolk County Department of Social…
June 9, 201117 N.Y.3d 380
Summary
The Court affirmed the Appellate Division's denial of Steven K.'s applications to proceed pro se in a parental‑rights termination proceeding, holding that his requests were neither unequivocal nor timely and therefore did not trigger the required searching inquiry. The opinion also noted that the constitutional right to self‑representation recognized in criminal cases does not automatically extend to family court termination actions.