A mother who had surrendered parental rights to six children challenged the denial of motions to vacate or reconsider the juvenile court’s termination order. She argued that she had been denied counsel at a hearing on those motions and had received ineffective assistance. The Georgia Court of Appeals held that the juvenile court could not resolve the motions without first determining whether the mother was indigent and entitled to appointed counsel. The record showed that counsel had sought to withdraw, the mother attempted to obtain new representation, and the court proceeded without making the required inquiry into her right to counsel. The appellate court vacated the denial of the post-termination motions and remanded. On remand, the juvenile court had to determine indigence, appoint counsel if necessary, and conduct a new hearing if the mother had exercised reasonable diligence.