O.M.

Introduction

The minor, A.M., was taken into protective custody in November 2006 based on allegations she had been abused by her father, O.M. (Father). In December 2007, the juvenile court issued jurisdiction and disposition orders sustaining the allegations of the petition, vesting sole physical custody with A.M.’s mother (Mother), and terminating jurisdiction with visitation orders granting Father monitored visits. A final custody order was entered in January 2008.

Father challenges the jurisdiction and disposition orders on a single ground: He contends the juvenile court erred by denying his requests to represent himself in propria persona.

We hold that in deciding whether to grant a parent’s request for self-representation in a juvenile dependency proceeding, the juvenile court must consider the child’s right to a prompt resolution of custody status. The juvenile court has discretion to deny the request when it is reasonably probable that self-representation will unduly delay the proceedings, impairing *918 the child’s right to a prompt resolution of custody status. The parent’s disruptive behavior may be sufficient, but is not necessary to deny the…