Samuel A., In re (2021) B306103 B306103; filed 9/21/21. ![[Files/CaseFiles/B306103.PDF]] [Opinion PDF](https://www.courts.ca.gov/opinions/archive/B306103.PDF) ## Rule excerpts Guardian ad litem appointment in dependency proceedings: inability to assist counsel distinguished from deliberate unwillingness to cooperate. > While necessary to protect the rights of an incompetent parent—an individual incapable of understanding the nature and purpose of the proceeding or unable to assist counsel in a rational manner—appointment of a guardian ad litem is not a tool to restrain a problematic parent, even one who unreasonably interferes with the orderly proceedings of the court or who persistently acts against her own interests or those of her child. — Samuel A., In re (2021) B306103, slip op., p. 2.