In Re CF, 340 S.W.3d 296

Father and Mother have two daughters, A.K. (1) and C.F. (8); both were on probation for manufacturing methamphetamine; police found active meth lab and drug paraphernalia in their home, leading to protective custody and foster placement of the children.
Father absented during adjudication and dispositional hearings due to incarceration; he later appeared pro se at case reviews and petitions for counsel were filed intermittently.
Children's Division initially denied Father’s request for counsel; Father participated minimally in hearings while incarcerated.
TPR petition filed March 8, 2010; trial court granted Father’s request for counsel on April 21, 2010; termination hearings held May 6 and May 13, 2010.
Trial court terminated parental rights on June 4, 2010; Father moved for rehearing alleging denial of counsel at prior hearings.
On appeal, the court reverses and remands for appointing counsel consistent with Section 211.211.4.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by denying court-appointed counsel to Father.	Father	State	Reversed; remanded for counsel appointment prior to proceedings.

In re N.S., 77 S.W.3d 655 (Mo.App. E.D.2002) (indigent custodian entitled to appointed counsel even when request after disposition)
In re M.A.J., 998 S.W.2d 177 (Mo.App. W.D.1999) (strict compliance with counsel rights in termination proceedings)
In re N.S., 77 S.W.3d 655 (Mo.App. E.D.2002) (reversal/remand when statutory criteria satisfied)
In re N.S., 77 S.W.3d 655 (Mo.App. E.D.2002) (indigent custodian entitled to appointed counsel even when request after disposition)
In re L.E.C., 182 S.W.3d 680 (Mo.App. W.D.2006) (custodian includes parent; right to appointed counsel)
In re J.S.W., 295 S.W.3d 877 (Mo.App. E.D.2009) (strict application of termination procedures; counsel rights emphasized)