In Martinez v. Court of Appeal of California (2000) 528 U.S. 152, the Supreme Court found the historical evidence insufficient to support a constitutional right to self-representation on appeal in a criminal case. "The historical evidence relied upon by Faretta as identifying a right of self-representation is not always useful because it pertained to times when lawyers were scarce, often mistrusted, and not readily available to the average person accused of crime. For one who could not obtain a lawyer, self-representation was the only feasible alternative to asserting no defense at all. Thus, a government's recognition of an indigent defendant's right to represent himself was comparable to bestowing upon the homeless beggar a 'right' to take shelter in the sewers of Paris." (Martinez v. Court of Appeal of Cal. Fourth Appellate Dist., supra, 528 U.S. at pp. 156-157.) The indigent parent facing a loss of parental rights faces no such stark alternatives, as he or she has an indisputable statutory right to counsel. Finally, the Martinez court found the respect for individual autonomy as a basis for a right of self-representation must be grounded in the due process clause where the Sixth Amendment did not apply. (Martinez v. Court of Appeal of Cal. Fourth Appellate Dist., supra, 528 U.S. at p. 160 120 S. Ct. at p. 690, 145 L. Ed. 2d at p. 606.) "Under the practices that prevail in the Nation today, however, we are entirely unpersuaded that the risk of either disloyalty or suspicion of disloyalty is a sufficient concern to conclude that a constitutional right of self-representation is a necessary component of a fair appellate proceeding." (Ibid.)