Cite as 2016 Ark. 131

SUPREME COURT OF ARKANSAS 

No.

IN RE ADMINISTRATIVE 

ORDER NUMBER 15.1 B

QUALIFICATIONS AND 

STANDARDS FOR ATTORNEYS 

APPOINTED TO REPRESENT 

CHILDREN AND PARENTS

Opinion Delivered March 17, 2016

PER CURIAM

Administrative Order Number 15.1 is amended, effective immediately, and 

republished as set out below. The amendments are to sections 1, 2, and 3, are illustrated in 

the End Note, and are summarized as follows: Section 1 (c) is amended to provide an 

individualized clinical component commensurate with each attorney=s experience. Sections 

2 and 3 are amended with respect to providing attorney contact information and clarifying 

attorney=s communication responsibilities. 

Administrative Order Number 15.1 -Qualifications and Standards for 

Attorneys Appointed to Represent Children and Parents 

Section 1. Qualifications for attorneys appointed by the court to represent children and 

indigent parents in dependency-neglect cases.

a. An attorney shall be licensed and in good standing with the Arkansas Supreme 

Court. 

b.(1) Prior to appointment, an attorney shall have initial education to include 
Cite as 2016 Ark. 131

2

approved legal education of not less than 10 hours in the two years prior to the 

date an attorney qualifies as a court-appointed attorney for children or indigent 

parents in dependency-neglect cases. Initial training must include: 

 Child development; 

 Dynamics of abuse and neglect; 

 Attorney roles & responsibilities, including ethical considerations; 

 Relevant state law, federal law, case law, and rules; 

 Family dynamics, which may include but is not limited to, the following topics: 

substance abuse, domestic violence and mental health issues; and 

 Division of Children and Family Services (DCFS) policies and procedures. 

 Additional initial legal education may include, but is not limited to: 

 Grief and attachment; 

 Custody and visitation; 

 Resources and services; and 

 Trial and appellate advocacy. 

(2) The Administrative Office of the Courts (AOC) shall design and conduct 

programs for the initial 10 hours of legal education, either alone or in collaboration with 

other agencies or entities. 

(3) Following completion of the initial 10 hours of legal education, continuing legal 

education (CLE) shall include at least 4 hours per year related to representation in 

dependency-neglect cases which may include, but is not limited to, the subject categories 

listed in (b)(1). The 4 hours of CLE may be in any one of the specified categories in (b)(1) 

or in any combination thereof. 

(4) Both the initial 10 hours of education and the 4 hours of CLE shall be certified 

in accordance with the rules and regulations promulgated by the Continuing Legal 

Education Board. All educational hours shall be calculated with reference to the CLE 
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3

reporting period of July 1 through June 30, as utilized for general CLE credit by the 

Continuing Legal Education Board. The CLE hours for attorneys may not be carried over 

from one CLE year to the next. 

(5) An attorney who is qualified for court appointment in dependency-neglect 

cases but who fails to acquire 4 hours of CLE required by June 30 of any year shall be subject 

to the pertinent compliance dates of Rule 5(D) of the Arkansas Rules and Regulations for 

Minimum Continuing Legal Education. In accordance with Rule 5.(D), attorneys who sign 

an acknowledgment deficiency by August 31, and obtain their 4 hours by December 1 shall 

remain qualified. However, such attorneys shall not be subject to the provisions of Section 

5 of the Regulations for Minimum Continuing Legal Education. 

(6) When an attorney is seeking to complete the 4-hour CLE requirement between 

June 30 and December 1 for the previous CLE year, he or she may remain as attorney on 

any pending cases for which appointment was made when the attorney was in compliance 

with the educational requirements. However, that attorney shall not accept appointment to 

any new cases until he or she is in full compliance with the CLE requirements. 

(7) An attorney who fails to complete 4 hours of CLE by December 1 is no longer 

qualified for court appointment in dependency-neglect cases. His or her name shall be 

removed from the list of qualified attorneys that is maintained and distributed to the trial 

courts by the AOC. Such attorney can become qualified again only by completing 10 hours 

of CLE in the categories required for initial qualification. 
Cite as 2016 Ark. 131

4

 (8) Attorneys in compliance with the educational qualifications as an attorney ad 

litem for dependency-neglect cases as of July 1, 2001 shall be deemed to have met the initial 

educational qualifications to represent parents in dependency-neglect cases. 

 c. Clinical prerequisite for new appointments in dependency-neglect cases. 

The Directors of the Attorney Ad Litem Program and Parent Counsel Program shall 

establish an individualized clinical prerequisite commensurate with each individual 

attorney=s experience that may include but is not limited to participation in staffings, 

mediation and hearings with an experienced attorney, and assigning an experienced attorney 

as mentor to the new attorney. Each attorney shall have a documented clinical plan approved 

by an attorney program director in their dependency-neglect qualification file. 

Section 2. Standards of practice for attorneys ad litem in dependency-neglect cases.

a. An attorney ad litem shall conduct personally or in conjunction with a trained Court 

Appointed Special Advocate (CASA) volunteer an independent investigation consisting of 

review of all relevant documents and records including but not limited to: police reports, 

DCFS records, medical records, school records, and court records. The ad litem shall 

interview the child, and in conjunction with a trained CASA volunteer, when one has been 

appointed, shall interview the parents, foster parents, caseworker, service providers, school 

personnel and others having relevant knowledge to assist in representation. Continuing 

investigation and regular contact with the child are mandatory. The attorney ad litem shall 

provide his or her clients and/or his or her client=s caregivers, the attorney=s contact 

information and shall respond promptly to all contacts concerning his or her client, 
Cite as 2016 Ark. 131

5

understanding that traditional methods of communication may vary depending on the 

client=s age and ability. 

 b. An attorney ad litem shall determine the best interest of a child by considering 

such factors as the child's age and sense of time, level of maturity, culture and ethnicity, 

degree of attachment to family members including siblings; as well as continuity, 

consistency, and the child's sense of belonging and identity. 

 c. An attorney shall make earnest efforts to attend all case staffings and court-ordered 

mediation conferences. Absent reasonable cause, the attorney shall directly communicate 

with his or her client and/or his or her client=s caregiver prior to the date of each hearing.

An attorney ad litem shall appear at all hearings to represent the best interest of the child. 

All relevant facts should be presented to the court and if the child's wishes differ from the 

ad litem's determination of the child's best interest, the ad litem shall communicate the child's 

wishes to the court. 

 d. An attorney ad litem shall explain the court proceedings and the role of the ad 

litem in terms that the child can understand. 

 e. An attorney ad litem shall advocate for specific and appropriate services for the 

child and the child's family. 

 f. An attorney ad litem shall monitor implementation of case plans and court orders. 

 g. An attorney ad litem shall file appropriate pleadings on behalf of the child. 
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6

 h. An attorney ad litem shall review the progress of the child's case and shall 

advocate for timely hearings. 

 i. An attorney ad litem shall request orders that are clear, specific, and, where 

appropriate, include a time line for assessment, services, placement, treatment and evaluation 

of the child and the child's family. 

 j. Attorney-client or any other privilege shall not prevent the ad litem from sharing 

all information relevant to the best interest of the child with the court. 

 k. An attorney ad litem, functioning as an arm of the court, is afforded immunity 

against ordinary negligence for actions taken in furtherance of his or her appointment. 

 l. An attorney ad litem shall participate in 10 hours of initial legal education prior to 

appointment and shall participate in 4 hours of CLE each year thereafter. 

 m. An attorney ad litem shall identify any potential or actual conflict of interest that 

would impair his or her ability to represent a client. The attorney shall notify the court as 

soon as practical of such conflict to allow the court to appoint another attorney for the client 

or for the client to retain counsel prior to the next hearing. 

 n. A full-time attorney shall not have more than 75 dependency-neglect cases, and a 

part-time attorney shall not have more than 25 dependency-neglect cases. Any deviations 

from this standard must be approved by the Administrative Office of the Courts which shall 

consider the following, including but not limited to: the number of counties and geographic 
Cite as 2016 Ark. 131

7

area in a judicial district, the experience and expertise of the attorney ad litem, area 

resources, the availability of CASA volunteers, the attorney's legal practice commitments 

and the proportion of the attorney's practice dedicated to representing children in 

dependency-neglect cases, the availability of qualified attorneys in the geographic area, and 

the availability of funding. An attorney who is within 5 cases of reaching the maximum 

caseload shall notify the Administrative Office of the Courts and the Juvenile Division Judge. 

 o. An attorney shall not accept appointment of any case for which he or she cannot 

devote the requisite amount of time to comply with the above Standards of Practice and the 

Model Rules of Professional Conduct. 

Section 3. Standards of practice for attorneys appointed by the court to represent parents in 

dependency-neglect cases.

a. An attorney shall conduct a review of all relevant documents and records including but 

not limited to: police reports, DCFS records, medical records, and court records. An 

attorney shall interview all people having relevant knowledge to assist in representation, 

including but not limited to the investigator, OCC attorney or DCFS case worker, and 

service providers. 

 b. The attorney shall provide his or her clients the attorney=s contact information and 

shall respond promptly to all contacts concerning his or her client. An attorney shall make 

earnest efforts to attend all case staffings and court-ordered mediation conferences. Absent 
Cite as 2016 Ark. 131

8

reasonable cause, the attorney shall directly communicate with his or her client prior to the 

date of each hearing. An attorney shall attend all dependency-neglect court hearings until 

the case is closed or his or her client's parental rights have been terminated. 

 c. An attorney shall diligently and zealously protect and advance the client's interests, 

rights and goals at all case staffings and in all court proceedings. 

 d. An attorney shall advise and explain to the client each stage of the court 

proceedings and the likelihood of achieving the client's goals. An attorney, where 

appropriate, shall identify alternatives for the client to consider, including the client's rights 

regarding any possible appeal, and explain the risks, if any, inherent in the client's position. 

 e. An attorney shall appear at all hearings and present all evidence and develop all 

issues to zealously advocate for his or her client and to further the client's goals. 

 f. An attorney shall advocate for specific and appropriate services for the parent to 

further the client's goals. 

 g. An attorney shall monitor implementation of case plans and court orders to further 

the client's goals. 

 h. An attorney shall file appropriate pleadings to further the client's goals. 

 i. An attorney shall review the progress of the client's case and shall advocate for 

timely hearings when necessary to further the client's goals. 

 j. An attorney shall request orders that are clear, specific, and, where appropriate, 
Cite as 2016 Ark. 131

9

include a time line for assessment, services, placement, and treatment. 

 k. An attorney shall participate in 10 hours of initial legal education prior to 

appointment and shall participate in 4 hours of CLE each year thereafter. 

 l. An attorney shall identify any potential or actual conflict of interest that would 

impair his or her ability to represent a client. The attorney shall notify the court as soon as 

practical of such conflict to allow the court to appoint another attorney for the client or for 

the client to retain counsel prior to the next hearing. 

 m. An attorney shall not accept appointment of any case for which he or she cannot 

devote the requisite amount of time to comply with the above Standards of Practice and the 

Model Rules of Professional Conduct. 

Section 4. Qualifications for attorneys appointed by the court to represent children in 

domestic relations cases and guardianship cases when custody is an issue. 

a. An attorney shall be licensed and in good standing with the Arkansas Supreme Court. 

 (1) Prior to appointment, an attorney shall have initial education to include approved 

legal education of not less than 10 hours in the two years prior to the date the attorney 

qualifies for appointment. Initial education shall include but is not limited to: 

 Child development; 

 Ad litem roles and responsibilities, including ethical considerations; 

 Relevant substantive state, federal and case law; 
Cite as 2016 Ark. 131

10

 Custody and visitation; and 

 Family dynamics, including substance abuse, domestic abuse, and mental health 

issues. 

 (2) The Administrative Office of the Courts shall design and conduct programs for 

the initial 10 hours of legal education, either alone or in collaboration with other agencies 

or entities. 

 (3) Continuing education required to maintain qualification as an attorney ad litem 

shall include 4 hours of annual education in any of the five subject-matter areas set out in 

(b)(1) above for initial training, or in other areas affecting the child and family. The 4 hours 

of CLE may be in any one of the specified categories or in any combination thereof. 

(4) Both the initial 10 hours of education and the 4 hours of CLE shall be certified as CLE 

in accordance with the rules and regulations promulgated by the Continuing Legal 

Education Board. All educational hours shall be calculated with reference to the CLE 

reporting period of July 1 through June 30, as utilized for general CLE credit by the 

Continuing Legal Education Board. The CLE hours for attorneys ad litem may not be 

carried over from one CLE year to the next. 

 (5) An attorney who is qualified as an attorney ad litem but who fails to acquire 4 

hours of CLE by June 30 of any year shall be subject to the pertinent compliance dates of 

Rule 5.(D) of the Arkansas Rules and Regulations for Minimum Continuing Legal 
Cite as 2016 Ark. 131

11

Education. In accordance with Rule 5.(D), attorneys who sign an acknowledgment of 

deficiency and obtain their four hours by December 1 shall remain qualified as attorneys ad 

litem. However, such attorneys shall not be subject to the provisions of Section 5 of the 

Regulations for Minimum Continuing Legal Education. 

 (6) When an attorney ad litem is seeking to complete the 4-hour continuing 

education requirement between June 30 and December 1 for the previous CLE year, he or 

she may remain as attorney ad litem on any pending cases for which appointment was made 

when the attorney was in compliance with educational requirements. However, that 

attorney shall not accept appointment to any new cases until he or she is in full compliance 

with the CLE requirements. 

 (7) An attorney who fails to complete 4 hours of CLE by December 1 is no longer 

qualified as an attorney ad litem. His or her name shall be removed from the list of qualified 

attorneys that is maintained and distributed to the trial courts by the AOC. Such attorney 

can become qualified again only by completing 10 hours in the categories required for initial 

qualification. 

Section 5. Standards of practice for attorneys ad litem in domestic relations cases and 

guardianship cases when custody is an issue.

a. An attorney ad litem shall conduct an independent investigation consisting of review of 

all relevant documents and records. The ad litem shall interview the child, parents, and 
Cite as 2016 Ark. 131

12

others having relevant knowledge to assist in representation. Continuing investigation and 

regular contact with the child during the pendency of the action are mandatory. Upon entry 

of a final order, the attorney ad litem's obligation to represent the minor child shall end, 

unless directed otherwise by the court. 

 b. An attorney ad litem shall determine the best interest of a child by considering 

such custody criteria as: 

 (1) Moral fitness factors: integrity, character, compassion, sobriety, religious training 

and practice, a newly acquired partner regarding the preceding elements; 

 (2) Stability factors: emotional stability, work stability, financial stability, residence 

and school stability, health, partner stability; 

 (3) Love and affection factors: attention given, discipline, attitude toward education, 

social attitude, attitude toward access of the other party to the child, and attitude toward 

cooperation with the other party regarding the child's needs; 

 (4) Other relevant information regarding the child such as stated preference, age, sex, 

health, testing and evaluation, child care arrangements; and regarding the home such as its 

location, size, and family composition. 

 c. An attorney ad litem shall appear at all hearings to represent the best interest of the 

child. All relevant facts should be presented to the court and if the child's wishes differ from 

the ad litem's determination of the child's best interest, the ad litem shall communicate the 
Cite as 2016 Ark. 131

13

child's wishes to the court, as well as the recommendations of the ad litem. 

 d. An attorney ad litem shall file appropriate pleadings on behalf of the child, call 

witnesses, participate fully in examination of witnesses, present relevant evidence, and 

advocate for timely hearings. 

 e. An attorney ad litem shall explain to the child the court proceedings and the role 

of the ad litem in terms that the child can understand. 

 f. An attorney ad litem shall make recommendations to the court for specific and 

appropriate services for the child and the child's family. All recommendations shall likewise 

be communicated to the attorneys for the parties, or if a party is pro se, then to the party. 

 g. An attorney ad litem shall not be prevented by any privilege, including the 

lawyer-client privilege, from sharing with the court all information relevant to the best 

interest of the child. 

 h. An attorney shall not accept appointment to any case for which he or she cannot 

devote the requisite amount of time to comply with these standards of practice and the 

Model Rules of Professional Conduct. 

END NOTE

Administrative Order Number 15.1 

Section 1. Qualifications for attorneys appointed by the court to represent children and 

indigent parents in dependency-neglect cases.
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14

a. An attorney shall be licensed and in good standing with the Arkansas Supreme Court. 

 b.(1) Prior to appointment, an attorney shall have initial education to include 

approved legal education of not less than 10 hours in the two years prior to the date an 

attorney qualifies as a court-appointed attorney for children or indigent parents in 

dependency-neglect cases. Initial training must include: 

 Child development; 

 Dynamics of abuse and neglect; 

 Attorney roles & responsibilities, including ethical considerations; 

 Relevant state law, federal law, case law, and rules; 

 Family dynamics, which may include but is not limited to, the following topics: 

substance abuse, domestic violence and mental health issues; and 

 Division of Children and Family Services (DCFS) policies and procedures. 

 Additional initial legal education may include, but is not limited to: 

 Grief and attachment; 

 Custody and visitation; 

 Resources and services; and 

 Trial and appellate advocacy. 

 (2) The Administrative Office of the Courts (AOC) shall design and conduct 

programs for the initial 10 hours of legal education, either alone or in collaboration with 
Cite as 2016 Ark. 131

15

other agencies or entities. 

 (3) Following completion of the initial 10 hours of legal education, continuing legal 

education (CLE) shall include at least 4 hours per year related to representation in 

dependency-neglect cases which may include, but is not limited to, the subject categories 

listed in (b)(1). The 4 hours of CLE may be in any one of the specified categories in (b)(1) 

or in any combination thereof. 

 (4) Both the initial 10 hours of education and the 4 hours of CLE shall be certified 

in accordance with the rules and regulations promulgated by the Continuing Legal 

Education Board. All educational hours shall be calculated with reference to the CLE 

reporting period of July 1 through June 30, as utilized for general CLE credit by the 

Continuing Legal Education Board. The CLE hours for attorneys may not be carried over 

from one CLE year to the next. 

 (5) An attorney who is qualified for court appointment in dependency-neglect cases 

but who fails to acquire 4 hours of CLE required by June 30 of any year shall be subject to 

the pertinent compliance dates of Rule 5.(D) of the Arkansas Rules and Regulations for 

Minimum Continuing Legal Education. In accordance with Rule 5.(D), attorneys who sign 

an acknowledgment deficiency by August 31, and obtain their 4 hours by December 1 shall 

remain qualified. However, such attorneys shall not be subject to the provisions of Section 

5 of the Regulations for Minimum Continuing Legal Education. 
Cite as 2016 Ark. 131

16

 (6) When an attorney is seeking to complete the 4-hour CLE requirement between 

June 30 and December 1 for the previous CLE year, he or she may remain as attorney on 

any pending cases for which appointment was made when the attorney was in compliance 

with the educational requirements. However, that attorney shall not accept appointment to 

any new cases until he or she is in full compliance with the CLE requirements. 

 (7) An attorney who fails to complete 4 hours of CLE by December 1 is no longer 

qualified for court appointment in dependency-neglect cases. His or her name shall be 

removed from the list of qualified attorneys that is maintained and distributed to the trial 

courts by the AOC. Such attorney can become qualified again only by completing 10 hours 

of CLE in the categories required for initial qualification. 

 (8) Attorneys in compliance with the educational qualifications as an attorney ad 

litem for dependency-neglect cases as of July 1, 2001 shall be deemed to have met the initial 

educational qualifications to represent parents in dependency-neglect cases. 

 c. Clinical prerequisite for new appointments in dependency-neglect cases. The 

Directors of the Attorney Ad Litem Program and Parent Counsel Program shall establish an 

individualized clinical prerequisite commensurate with each individual attorney=s experience 

that may include but is not limited to participation in staffings, mediation and hearings with 

an experienced attorney, and assigning an experienced attorney as mentor to the new 

attorney. Each attorney shall have a documented clinical plan approved by an attorney 
Cite as 2016 Ark. 131

17

program director in their dependency-neglect qualification file. 

 (1) Attorneys ad litem: Assistance in representation of a child with an experienced 

attorney in the following hearings: 

 Emergency; 

 Adjudication/Disposition; 

 Review; 

 Permanency Planning; and 

 Termination of Parental Rights. 

 (2) Parent counsel: Assistance in representation of a parent with an experienced 

attorney in the following hearings: 

 Emergency; 

 Adjudication/Disposition; 

 Review; 

 Permanency Planning; and 

 Termination of Parental Rights. 

Section 2. Standards of practice for attorneys ad litem in dependency-neglect cases.

a. An attorney ad litem shall conduct personally or in conjunction with a trained Court 

Appointed Special Advocate (CASA) volunteer an independent investigation consisting of 

review of all relevant documents and records including but not limited to: police reports, 
Cite as 2016 Ark. 131

18

DCFS records, medical records, school records, and court records. The ad litem shall 

interview the child, and in conjunction with a trained CASA volunteer, when one has been 

appointed, shall interview the parents, foster parents, caseworker, service providers, school 

personnel and others having relevant knowledge to assist in representation. Continuing 

investigation and regular contact with the child are mandatory. The attorney ad litem shall 

provide his or her clients and/or his or her client=s caregivers, the attorney=s contact 

information and shall respond promptly to all contacts concerning his or her client, 

understanding that traditional methods of communication may vary depending on the 

client=s age and ability. 

 b. An attorney ad litem shall determine the best interest of a child by considering 

such factors as the child's age and sense of time, level of maturity, culture and ethnicity, 

degree of attachment to family members including siblings; as well as continuity, 

consistency, and the child's sense of belonging and identity. 

 c. An attorney shall make earnest efforts to attend all case staffings and court-ordered 

mediation conferences. and to meet with his or her client prior to every hearing. Absent 

reasonable cause, the attorney shall directly communicate with his or her client and/or his 

or her client=s caregiver prior to the date of each hearing. An attorney ad litem shall appear 

at all hearings to represent the best interest of the child. All relevant facts should be presented 

to the court and if the child's wishes differ from the ad litem's determination of the child's 
Cite as 2016 Ark. 131

19

best interest, the ad litem shall communicate the child's wishes to the court. 

 d. An attorney ad litem shall explain the court proceedings and the role of the ad 

litem in terms that the child can understand. 

 e. An attorney ad litem shall advocate for specific and appropriate services for the 

child and the child's family. 

 f. An attorney ad litem shall monitor implementation of case plans and court orders. 

 g. An attorney ad litem shall file appropriate pleadings on behalf of the child. 

 h. An attorney ad litem shall review the progress of the child's case and shall advocate 

for timely hearings. 

 i. An attorney ad litem shall request orders that are clear, specific, and, where 

appropriate, include a time line for assessment, services, placement, treatment and evaluation 

of the child and the child's family. 

 j. Attorney-client or any other privilege shall not prevent the ad litem from sharing 

all information relevant to the best interest of the child with the court. 

 k. An attorney ad litem, functioning as an arm of the court, is afforded immunity 

against ordinary negligence for actions taken in furtherance of his or her appointment. 

 l. An attorney ad litem shall participate in 10 hours of initial legal education prior to 

appointment and shall participate in 4 hours of CLE each year thereafter. 

 m. An attorney ad litem shall identify any potential or actual conflict of interest that 
Cite as 2016 Ark. 131

20

would impair his or her ability to represent a client. The attorney shall notify the court as 

soon as practical of such conflict to allow the court to appoint another attorney for the client 

or for the client to retain counsel prior to the next hearing. 

 n. A full-time attorney shall not have more than 75 dependency-neglect cases, and a 

part-time attorney shall not have more than 25 dependency-neglect cases. Any deviations 

from this standard must be approved by the Administrative Office of the Courts which shall 

consider the following, including but not limited to: the number of counties and geographic 

area in a judicial district, the experience and expertise of the attorney ad litem, area 

resources, the availability of CASA volunteers, the attorney's legal practice commitments 

and the proportion of the attorney's practice dedicated to representing children in 

dependency-neglect cases, the availability of qualified attorneys in the geographic area, and 

the availability of funding. An attorney who is within 5 cases of reaching the maximum 

caseload shall notify the Administrative Office of the Courts and the Juvenile Division Judge. 

 o. An attorney shall not accept appointment of any case for which he or she cannot 

devote the requisite amount of time to comply with the above Standards of Practice and the 

Model Rules of Professional Conduct. 

Section 3. Standards of practice for attorneys appointed by the court to represent parents in 

dependency-neglect cases.

a. An attorney shall conduct a review of all relevant documents and records including but 
Cite as 2016 Ark. 131

21

not limited to: police reports, DCFS records, medical records, and court records. An 

attorney shall interview all people having relevant knowledge to assist in representation, 

including but not limited to the investigator, OCC attorney or DCFS case worker, and 

service providers. 

 b. The attorney shall provide his or her clients the attorney=s contact information and 

shall respond promptly to all contacts concerning his or her client. An attorney shall make 

earnest efforts to attend all case staffings and court-ordered mediation conferences and to 

meet with his or her client prior to every hearing. Absent reasonable cause, the attorney 

shall directly communicate with his or her client prior to the date of each hearing. An 

attorney shall attend all dependency-neglect court hearings until the case is closed or his or 

her client's parental rights have been terminated.

. . . .