Parent's Right to Appointed Trial Counsel In a Dependency Case

As was explained in In re Meranda P. (1997) 56 Cal. App. 4th 1143, 1153, footnote 6 65 Cal. Rptr. 2d 913, "An indigent parent in a state-initiated dependency, which is civil in nature, has no general right under either the federal or the state Constitution to the assistance of appointed trial counsel at every stage of the proceeding. But the appointment of counsel is a constitutional imperative . . . when . . . fundamental fairness requires such an appointment. Whether fundamental fairness is likely to be a hazard is determined by weighing, one against the other, . . . (1) the private interests at stake; (2) the government's interest; (3) the risk that the procedures used will lead to erroneous decisions. The inquiry necessitates consideration of the factual circumstances and the procedural setting of the case at the time when the error is said to have occurred."