In re P.D.R.

by
The parental rights of Mother to her three children were terminated after a trial in which she waived her right to counsel. The court of appeals vacated the trial court's order and ordered a new termination proceeding, concluding that the trial court abused its discretion by allowing Mother to waive counsel because the court failed to conduct an adequate inquiry under N.C. Gen. Stat. 15A-1242. The Supreme Court reversed the decision of the court of appeals, holding that section 15A-1242, a criminal statute, has no application in termination of parental rights proceedings. Remanded to the court of appeals to decide whether the role of a guardian ad litem is one of assistance or substitution, one of the issues presented on appeal.