In the Matter of Kathleen K., a Child Alleged to Be Permanently Neglected. Suffolk County Department of Social…

Summary

The Court affirmed the Appellate Division’s order denying Steven K.’s applications to proceed pro se in the termination of parental‑rights proceeding, holding that his requests were not unequivocal and, for the second request, untimely, and therefore the trial court was not required to conduct a searching inquiry. The decision relied on the established requirements for a criminal defendant’s self‑representation waiver and found they were not satisfied. A concurring opinion agreed with the result but argued that the request was clear and that the Faretta right does not extend to family‑court termination cases.