J.B.'s parental rights over his four children were terminated after he failed to appear at an initial status hearing to say whether he consented to the termination. At the termination proceeding itself, however, he appeared, objected to the termination, and asked for an attorney. The trial judge denied his request and terminated his rights. On appeal, J.B. argued that the notice for the status hearing was insufficient and violated his due process rights. The First District Court reversed and remanded the case to the trial court, allowing J.B., with the assistance of counsel, to attempt to set aside the termination. The trial court denied his requests and entered a second termination order. On appeal,. the District Court concluded that the twenty-four hours's notice was sufficient to meet minimum due process requirements, and affirmed the trial court's ruling.