termination of parental rights hearing (Georgia) · Go Syfert
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termination of parental rights hearing in Georgia

7 Georgia opinions name it 1 courts 1999–2025 1 in the last five years

The cases below were cited by Georgia courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (12)

CaseFollowedCited
In the Interest of J. M. B.green
gactapp · 2009 · cited in 3 Georgia opinions naming this issue, 2010–2011
2 sentences

2011B., 296 Ga. App. 786, 791 ( 676 SE2d 9 ) (2009) (denial of counsel during the termination of parental rights hearing not subject to harmless error analysis).

2010B., 296 Ga. App. 786, 791 ( 676 SE2d 9 ) (2009) (concerning denial of counsel during the termination of parental rights hearing).

33
Skipper v. Smithgreen
ga · 1977 · cited in 2 Georgia opinions naming this issue, 1999–1999
2 sentences

1999After a finding of subterfuge, “nothing would preclude the court from proceeding with the termination-of-parental-rights hearing.” Skipper v. Smith, 239 Ga. 854, 857 (2) ( 238 SE2d 917 ) (1977). 3.

1999After a finding of subterfuge, “nothing would preclude the court from proceeding with the termination-of-parental-rights hearing.” Skipper v. Smith, 239 Ga. 854, 857 (2) ( 238 SE2d 917 ) (1977). 3.

22
In Re JMBgreen
gactapp · 2009 · cited in 3 Georgia opinions naming this issue, 2010–2011
2 sentences

2011B., 296 Ga. App. 786, 791 ( 676 SE2d 9 ) (2009) (denial of counsel during the termination of parental rights hearing not subject to harmless error analysis).

2010B., 296 Ga. App. 786, 791 ( 676 SE2d 9 ) (2009) (concerning denial of counsel during the termination of parental rights hearing).

13
In the Interest of K. C. W.green
gactapp · 2009 · cited in 1 Georgia opinions naming this issue, 2025–2025
1 sentence

2025W., 297 Ga. App. 714, 717 (1) ( 678 SE2d 343 ) (2009) (where prior proceedings in the case made clear that the father’s mental capacity was an issue, the father could not claim “unfair surprise” when evidence on that issue was introduced at the termination of parental rights hearing). (b) During her cross-examination of the Department investigator, the father’s attorney asked if the mother had admitted to killing A. J.

11
In Re MEgreen
gactapp · 2004 · cited in 1 Georgia opinions naming this issue, 2010–2010
2 sentences

2010Under Court of Appeals Rule 25(c)(2)(iii), references to the record must be both to a specific volume or part of the record and by specific page number. [33] In the Interest of J.P.V., 261 Ga.App. 194, 196 (2), 582 S.E.2d 170 (2003). [34] See id. (juvenile court was authorized to consider prior unappealed orders entered in the case); see also In the Interest of M.E., 265 Ga. App. 412, 420 (3)(a), 593 S.E.2d 924 (2004) (failure to make a meritless objection cannot be evidence of ineffective assistance of counsel). [35] See Division 4(b), supra. [36] In the Interest of O.M.J., 297 Ga.App. 20, 28

2010Under Court of Appeals Rule 25(c)(2)(iii), references to the record must be both to a specific volume or part of the record and by specific page number. [33] In the Interest of J.P.V., 261 Ga.App. 194, 196 (2), 582 S.E.2d 170 (2003). [34] See id. (juvenile court was authorized to consider prior unappealed orders entered in the case); see also In the Interest of M.E., 265 Ga. App. 412, 420 (3)(a), 593 S.E.2d 924 (2004) (failure to make a meritless objection cannot be evidence of ineffective assistance of counsel). [35] See Division 4(b), supra. [36] In the Interest of O.M.J., 297 Ga.App. 20, 28

11
In the Interest of C. T.green
gactapp · 2007 · cited in 1 Georgia opinions naming this issue, 2010–2010
1 sentence

2010Compare In the Interest of J.M.B., 296 Ga.App. 786, 791 , 676 S.E.2d 9 (2009) (concerning denial of counsel during the termination of parental rights hearing). [32] See In the Interest of C.T., 286 Ga.App. 186, 187 (1), 648 S.E.2d 708 (2007).

11
In the Interest of R. S.green
gactapp · 2007 · cited in 1 Georgia opinions naming this issue, 2010–2010
1 sentence

2010Under Court of Appeals Rule 25(c)(2)(iii), references to the record must be both to a specific volume or part of the record and by specific page number. [33] In the Interest of J.P.V., 261 Ga.App. 194, 196 (2), 582 S.E.2d 170 (2003). [34] See id. (juvenile court was authorized to consider prior unappealed orders entered in the case); see also In the Interest of M.E., 265 Ga. App. 412, 420 (3)(a), 593 S.E.2d 924 (2004) (failure to make a meritless objection cannot be evidence of ineffective assistance of counsel). [35] See Division 4(b), supra. [36] In the Interest of O.M.J., 297 Ga.App. 20, 28

11
In the Interest of O. M. J.green
gactapp · 2009 · cited in 1 Georgia opinions naming this issue, 2010–2010
1 sentence

2010Under Court of Appeals Rule 25(c)(2)(iii), references to the record must be both to a specific volume or part of the record and by specific page number. [33] In the Interest of J.P.V., 261 Ga.App. 194, 196 (2), 582 S.E.2d 170 (2003). [34] See id. (juvenile court was authorized to consider prior unappealed orders entered in the case); see also In the Interest of M.E., 265 Ga. App. 412, 420 (3)(a), 593 S.E.2d 924 (2004) (failure to make a meritless objection cannot be evidence of ineffective assistance of counsel). [35] See Division 4(b), supra. [36] In the Interest of O.M.J., 297 Ga.App. 20, 28

11
In Re CTgreen
gactapp · 2007 · cited in 1 Georgia opinions naming this issue, 2010–2010
1 sentence

2010Compare In the Interest of J.M.B., 296 Ga.App. 786, 791 , 676 S.E.2d 9 (2009) (concerning denial of counsel during the termination of parental rights hearing). [32] See In the Interest of C.T., 286 Ga.App. 186, 187 (1), 648 S.E.2d 708 (2007).

11
In Re Rsgreen
gactapp · 2007 · cited in 1 Georgia opinions naming this issue, 2010–2010
1 sentence

2010Under Court of Appeals Rule 25(c)(2)(iii), references to the record must be both to a specific volume or part of the record and by specific page number. [33] In the Interest of J.P.V., 261 Ga.App. 194, 196 (2), 582 S.E.2d 170 (2003). [34] See id. (juvenile court was authorized to consider prior unappealed orders entered in the case); see also In the Interest of M.E., 265 Ga. App. 412, 420 (3)(a), 593 S.E.2d 924 (2004) (failure to make a meritless objection cannot be evidence of ineffective assistance of counsel). [35] See Division 4(b), supra. [36] In the Interest of O.M.J., 297 Ga.App. 20, 28

11
In Re Jpvgreen
gactapp · 2003 · cited in 1 Georgia opinions naming this issue, 2010–2010
2 sentences

2010Under Court of Appeals Rule 25(c)(2)(iii), references to the record must be both to a specific volume or part of the record and by specific page number. [33] In the Interest of J.P.V., 261 Ga.App. 194, 196 (2), 582 S.E.2d 170 (2003). [34] See id. (juvenile court was authorized to consider prior unappealed orders entered in the case); see also In the Interest of M.E., 265 Ga. App. 412, 420 (3)(a), 593 S.E.2d 924 (2004) (failure to make a meritless objection cannot be evidence of ineffective assistance of counsel). [35] See Division 4(b), supra. [36] In the Interest of O.M.J., 297 Ga.App. 20, 28

2010Under Court of Appeals Rule 25(c)(2)(iii), references to the record must be both to a specific volume or part of the record and by specific page number. [33] In the Interest of J.P.V., 261 Ga.App. 194, 196 (2), 582 S.E.2d 170 (2003). [34] See id. (juvenile court was authorized to consider prior unappealed orders entered in the case); see also In the Interest of M.E., 265 Ga. App. 412, 420 (3)(a), 593 S.E.2d 924 (2004) (failure to make a meritless objection cannot be evidence of ineffective assistance of counsel). [35] See Division 4(b), supra. [36] In the Interest of O.M.J., 297 Ga.App. 20, 28

11
In Re Omjgreen
gactapp · 2009 · cited in 1 Georgia opinions naming this issue, 2010–2010
1 sentence

2010Under Court of Appeals Rule 25(c)(2)(iii), references to the record must be both to a specific volume or part of the record and by specific page number. [33] In the Interest of J.P.V., 261 Ga.App. 194, 196 (2), 582 S.E.2d 170 (2003). [34] See id. (juvenile court was authorized to consider prior unappealed orders entered in the case); see also In the Interest of M.E., 265 Ga. App. 412, 420 (3)(a), 593 S.E.2d 924 (2004) (failure to make a meritless objection cannot be evidence of ineffective assistance of counsel). [35] See Division 4(b), supra. [36] In the Interest of O.M.J., 297 Ga.App. 20, 28

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Georgia. Read the followed side critically anyway.

Also cited on this issue (2)

CaseCitedYears
In Re KCW green
gactapp · 2009
1 sentence

2025W., 297 Ga. App. 714, 717 (1) ( 678 SE2d 343 ) (2009) (where prior proceedings in the case made clear that the father’s mental capacity was an issue, the father could not claim “unfair surprise” when evidence on that issue was introduced at the termination of parental rights hearing). (b) During her cross-examination of the Department investigator, the father’s attorney asked if the mother had admitted to killing A. J.

12025–2025
Mabou v. Eller green
gactapp · 1998
1 sentence

2011Cf. id. at 636-637 (1), 502 S.E.2d 760 (finding that the emotional and financial pressures the mother may have been under when she made decision to surrender her parental rights under adoption statute were not unusual under the circumstances and did not amount to legal duress that would permit the mother to withdraw her surrender outside the grace period written into the adoption statute).

12011–2011

Statutes the citing opinions construe

GA § 15-11-58 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CT 75 (1979–2024) NC 67 (2002–2026) PA 43 (1997–2026) AL 31 (1987–2017) NJ 21 (2000–2022) IA 21 (1990–2026) IN 13 (1991–2019) IL 13 (2003–2026) UT 11 (1997–2020) MO 11 (1988–2023) CO 11 (2007–2026) CA 9 (1995–2022) AR 9 (2007–2024) HI 8 (2021–2026) NM 8 (2007–2023) GA 7 (1999–2025) NE 5 (1987–2016) DE 4 (2002–2025) WI 4 (1991–1992) VT 4 (2012–2017) MI 4 (2010–2019) RI 3 (2001–2011) OK 3 (1997–2021) ME 3 (2018–2020) MT 3 (1995–2001) FL 3 (1998–2025) ND 3 (1976–2007) TN 2 (2017–2020) DC 2 (2003–2018) WY 2 (2021–2022)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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