A juvenile court terminated Alisha Holloway’s parental rights after she appeared without counsel. Georgia guarantees parents counsel at every stage of a termination proceeding, but the record did not show a valid waiver of that right. The Court of Appeals vacated the judgment and directed the juvenile court to determine whether Holloway knowingly waived counsel or lost the right by failing to make reasonable efforts to retain a lawyer. If she did not, the court must hold a new termination hearing; if she did, it may reenter its judgment, which Holloway could seek to appeal. The appellate court did not decide whether the evidence otherwise justified termination or reach her remaining claims. The decision makes the right-to-counsel inquiry a necessary step before a termination judgment can stand.