In re: M.M. & A.M.

CourtCourt of Special Appeals of Maryland
DecidedAugust 28, 2025
Docket2458/24
StatusPublished

This text of In re: M.M. & A.M. (In re: M.M. & A.M.) is published on Counsel Stack Legal Research, covering Court of Special Appeals of Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re: M.M. & A.M., (Md. Ct. App. 2025).

Opinion

In re M.M. & A.M., No. 2458, September Term 2024. Opinion by Zic, J.

GUARDIANSHIP PROCEEDINGS – TERMINATION OF PARENTAL RIGHTS – UNTIMELY OBJECTION

Pursuant to Maryland Rule 11-307(b)(2), in determining whether “good cause” exists to accept an untimely objection, a juvenile court may consider, among other circumstances and as appropriate, excusable neglect or mistake, serious physical or mental injury, a parent’s location out of state, inability to retain counsel in a complex case, ignorance of the notice requirement, and misleading representations by a government representative.

THE PUBLIC DEFENDER ACT – GUARDIANSHIP PROCEEDINGS – RIGHT TO COUNSEL

Section 16-204(b)(1)(vi) of the Criminal Procedure Article of the Maryland Code (2001, 2018 Repl. Vol., 2020 Supp.) entitles parents who have not consented to the termination of their parental rights to counsel during the guardianship proceedings.

GUARDIANSHIP PROCEEDINGS – TERMINATION OF PARENTAL RIGHTS – MOTIONS

Pursuant to Maryland Rule 11-104(e), juvenile courts cannot consider facts that are not supported by either the record or an affidavit accompanying a motion. Circuit Court for Baltimore City Case No. T24121002 Case No. T24121003

REPORTED

IN THE APPELLATE COURT

OF MARYLAND

No. 2458

September Term, 2024 ______________________________________

IN RE: M.M. & A.M. ______________________________________

Reed, Zic, Albright,

JJ. ______________________________________

Opinion by Zic, J. ______________________________________

Filed: August 28, 2025

Pursuant to the Maryland Uniform Electronic Legal Materials Act (§§ 10-1601 et seq. of the State Government Article) this document is authentic.

2025.08.28 15:09:59 -04'00' Gregory Hilton, Clerk This appeal arises from guardianship proceedings in the Circuit Court for

Baltimore City. Father, appellant, is the parent of two minor children, M.M. and A.M.

(collectively, “Children”). On May 2, 2024, the Baltimore City Department of Social

Services (“Department”) filed guardianship petitions for the Children. Father’s counsel,

C., entered her appearance in the guardianship matter on Father’s behalf on July 2, 2024.

Father was served with the guardianship petitions and corresponding show cause orders

on October 2, 2024. C. filed an untimely objection on January 8, 2025, which the court,

sitting as a juvenile court, struck four days later following a hearing.

On February 13, 2025, an Assistant Public Defender with the Maryland Office of

the Public Defender (“OPD”), L., entered her appearance on Father’s behalf and asked

the court to reconsider Father’s untimely objection, arguing that C. provided ineffective

assistance of counsel. The court declined to consider L.’s motion for reconsideration,

found that Father consented to the guardianship proceedings, and terminated Father’s

parental rights. Father now appeals.

QUESTIONS PRESENTED

Father presents two questions for our review, which we have rephrased as

follows: 1 0F

1 Father phrased the questions as follows: 1. Whether the Juvenile Court erred in striking Father’s Notice of Objection and denying the Motion to Reconsider Striking of Objection. 2. Whether failure of Father’s Counsel in the Guardianship case to file a timely objection in the Guardianship case (continued) 1. Whether the juvenile court abused its discretion in striking Father’s untimely objection.

2. Whether the juvenile court abused its discretion in denying Father’s motion for reconsideration.

For the following reasons, we affirm.

BACKGROUND

This case concerns siblings M.M. (born in 2023) and A.M. (born in 2021), who

have been in the Department’s custody for all but a few days of their lives. A.M. was

born drug-exposed and removed from his parents’ care nine days after his birth due to

substance abuse and mental health concerns. M.M. was similarly removed 13 days after

his birth. M.M. and A.M. were separately found to be Children in Need of Assistance

(“CINA”), and have remained in foster care since their removals. Both reside with

long-term adoptive resources.

The Guardianship Proceedings

On May 3, 2024, the Department filed petitions for the Children, seeking

guardianship with the right to consent to adoption. 2 At a scheduling conference on July 1F

2, 2024, Father’s CINA attorney, B., informed the circuit court that he would not be

representing Father in the guardianship proceedings. At the same hearing, C., a panel

attorney assigned by the OPD, entered her appearance on Father’s behalf.

and failure to communicate at all with Father deprived Father of his right to counsel in the Guardianship proceeding. 2 The Children’s mother withdrew her objection to the guardianship proceedings and is not involved in the present appeal.

2 On July 15, 2024, the Department served B. with the guardianship petitions.

Father, who became incarcerated after the petitions were filed, was personally served on

October 2, 2024. The accompanying show cause orders informed Father that he had 30

days to file an objection. The court held a status conference on October 28, 2024, a few

days before Father’s objection deadline. Father appeared at this status conference in

person, and C. appeared virtually but did not file a timely objection on Father’s behalf.

Following instruction from the OPD, C. filed an objection on January 8, 2025.

The Department moved to strike the objection as untimely, and C. did not respond. At

the hearing on the Department’s motion to strike, C. offered speculation about why

Father had not objected but admitted that she had not consulted with him about his

wishes. C. stated that she had never spoken to Father, although she had “tried calling him

several, several, several times.” She ultimately asked the court “in equity” to permit

Father’s untimely objection. The court granted the Department’s motion to strike,

finding no circumstances that could justify the 68-day delay in filing Father’s objection.

Motion For Reconsideration

In early February 2025, L. entered her appearance on Father’s behalf and filed a

motion for reconsideration. The motion argued that C. rendered ineffective assistance of

counsel by failing to consult with Father about whether to object, failing to file a timely

objection, and failing to properly respond to the Department’s motion to strike. L. did

not file an accompanying affidavit pursuant to Maryland Rule 11-104(e).

At the February 18, 2025 termination of parental rights (“TPR”) hearing, the court

declined to consider Father’s ineffective assistance claim. The court explained that

3 Father’s statutory right to counsel under the Public Defender Act 3 had not yet “kicked in” 2F

because Father had not filed an objection:

I think that under the circumstances, it’s not clear to me that the statutory right to a Public Defender ever attached in this case because it should have -- what should’ve happened is after the paperwork, the TPR action was filed by DSS. It was up to [Father] to do one of several different things. One, file an objection. It’s spelled out in very simple language [in the show cause orders . . . .]

And two, upon filing an objection, or even frankly without filing an objection, apply for representation through the [OPD], which is also spelled out in the order that is sent to people when a TPR action is filed.

***

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Bluebook (online)
In re: M.M. & A.M., Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-mm-am-mdctspecapp-2025.