Stating there is a fine line between being a "difficult client" and being a client whose conduct forfeits the right to court-appointed counsel, Florida's Fourth District Court of Appeal upheld Broward Circuit Court Judge Yael Gamm's lower court ruling that denied a father his appeal over the termination of his parental rights.

K.R., the father, appealed the termination-of-parental-rights final judgment against him, arguing that the lower court's failure to appoint trial counsel without charge to him constituted a denial of due process.

Broward County Circuit Judge Yael Gamm. Photo: J. Albert Diaz/ALM