In re B.L.H., 239 N.C. App. 52 (2015)

Vacated and Remanded in Part

  • Relying on Dunkley v. Shoemate, 350 N.C. 573 (1999), which held “a lawyer cannot properly represent a client with whom he has no contact,” counsel in this case was unable to present evidence or make substantive arguments on his client’s behalf such that this father was denied fundamental fairness in the termination of parental rights action.
  • Counsel is required to make sufficient efforts to communicate with his client, which includes attempts to call, write, and/or email the client.


Termination of Parental Rights
Appointment of Counsel
Ineffective Assistance of Counsel
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