In re L.Z.S.

Summary

The Court held that the trial court improperly permitted appointed counsel to withdraw on the day of a permanency planning hearing without record evidence that respondent-father received reasonable notice or that the court adequately investigated the basis for withdrawal. Because respondent-father consequently lacked counsel when reunification was discontinued, the Court reversed the withdrawal and reunification orders and remanded for a new permanency planning hearing. The termination-of-parental-rights orders were left undisturbed unless the remand proceedings determine that reunification efforts were improperly discontinued.