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IN RE WELFARE OF G.L.H.

No. C8-99-1345.

614 N.W.2d 718 (2000)

In the Matter of the WELFARE OF G.L.H., G.E.H., Jr.

Supreme Court of Minnesota.

July 20, 2000.

Attorney(s) appearing for the Case

Susan Gaertner, Ramsey County Atty., Gwen Werner, Asst. Ramsey County Atty., Kelli Duehning, Certified Student Atty., St. Paul, for appellant.

Lochlan T. Stuart, St. Paul, for respondent.

Karen Garvin, St. Paul, Guardian Ad Litem.

Kenneth A. Malvey, Asst. Dakota County Atty., Hastings, for amicus curiae Minn. County Attys. Assn.

Considered and decided by the court en banc without oral argument.

OPINION

BLATZ, Chief Justice.

Respondent dismissed her court-appointed counsel on the day of her termination of parental rights (TPR) trial, and argues that her decision to do so did not constitute a voluntary and intelligent waiver of her statutory right to counsel. Because we conclude that determining the validity of a parent's waiver of counsel does not require application of the waiver procedure in the Minnesota Rules of Criminal Procedure, and can be...

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