In the Interest of KMM
In In the Interest of KMM, 957 P.2d 296 (Wyo. 1998), the father complained on appeal about the district court's failure to appoint an attorney to represent him at the termination hearing. Id. at 297.
The Court noted that, while pro se litigants are entitled to some leniency, "the proper administration of justice requires reasonable adherence to the rules and requirements of the court." Id. at 298. Nevertheless, the Court ruled that, because the father in KMM did not file a proper motion for appointment of counsel, he could not complain about his lack of counsel. Id.
The Court noted, in particular, that "the fact that the father filed several motions in this case convinces us that his failure to file a motion for a court appointed attorney was not the result of his inability to understand the procedural requirement." Id.