Periodic CHINS placement review was transformed into a modification proceeding, so that court’s modification contrary to DCS recommendation was subject to expedited appeal procedure.
Juvenile
R.W. v. State, No. 31A05-0803-JV-161, __ N.E.2d ___ (Ind. Ct. App., Feb. 19, 2009)
Delinquency initial hearing record did not show juvenile was given a meaningful opportunity to confer with his parent before they waived his right to counsel.