In a Decision – Div. of Child Protection & Permanency v. R.L.M. (a "Reported Decision") >> the Court Held:
The Appellate Division determined that a parent has the constitutional right to represent him/herself in a termination of parental rights matter.
A parent's decision to appear pro se in such complex and consequential litigation was poor strategy, but N.J.S.A 30:4C-15.4 plainly authorized a parent to proceed unrepresented. However, that right had to be exercised in a manner that allowed a full and fair adjudication and a prompt and equitable permanency determination for the child. The parent had to clearly invoke the right to self-representation in a timely manner and the court had to ensure the parent understood the problems in self-representation. In this case, father did not assert his right until the trial was in progress and the trial court properly denied the claim as untimely.