In re M.G., 239 N.C. App. 77 (2015)

Vacated and Remanded

  • After appearing in an action, an attorney may only withdraw if all three prongs are satisfied: 1) justifiable cause, 2) reasonable notice to the client, and 3) permission of the court.  Without any evidence that counsel notified or attempted to notify her client of her intent to withdraw, it is an abuse of discretion for a court to grant the attorney’s motion to withdraw.
  • Reaffirming In re D.E.G., 747 S.E. 2d 285 (2013), a parent who is represented by an attorney in an underlying A/N/D action continues to be represented by that attorney in the TPR action, and therefore, the attorney is not provisionally appointed in the TPR.


Termination of Parental Rights
Appointment of Counsel
Withdrawal of Counsel
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