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Name: In re A.M.
Case #: G039713
Court: CA Court of Appeal
District 4 DCA
Division: 3
Opinion Date: 07/10/2008
Summary

The trial court did not err by denying a father’s request to represent himself in the dependency proceeding. The father appealed the jurisdiction and disposition orders, contending that the juvenile court erred in denying his request to represent himself. The appellate court rejected his argument, finding that in a dependency proceeding, the right to represent oneself is statutory, not constitutional. The statutory right must always be weighed against the child’s right to a prompt resolution of the proceedings. The juvenile court has the discretion to deny the request where it may impair the child’s right to a prompt resolution of custody status or would disrupt the proceedings. Here, there was ample evidence that granting the father’s requests for self-representation would unduly delay the dependency proceedings and impair the minor’s right to a speedy resolution. The trial court did not err by denying the requests. Further, any error would have been harmless. The father denied all of the allegations. Granting the request would not have made father’s testimony more credible.