In Lassiter v. Dept. of Social Srvcs. of Durham Co., 452 U.S. 18, 101 S. Ct. 2153, 68 L. Ed. 2d 640 (1981), the United States Supreme Court took up the question of whether due process requires that an indigent parent be represented by court-appointed counsel when faced with a suit for involuntary termination of their parental rights. Id. The court concluded that no absolute right to counsel exists, but that under certain circumstances, fundamental fairness may require the appointment of counsel in a termination proceeding. Lassiter, 452 U.S. at 31-32. While the court noted that a "parent's interest in the accuracy and injustice of the decision to terminate his or her parental status is, . . . a commanding one," this interest must be balanced against the presumption that there is no right to appointed counsel in the absence of at least a potential deprivation of physical liberty. Id. at 28, 32. The court found that the trial did not violate fundamental fairness, noting that the petition for termination did not contain an allegation upon which criminal charges could be based, the presence of counsel could not have made a significant difference in the effect of the evidence that neither the mother nor the grandmother was interested in the well-being of the child, and that the mother had not bothered to appear for a previous custody hearing. Ultimately, the court said, "the decision whether due process calls for the appointment of counsel for indigent parents in termination proceedings is to be answered in the first instance by the trial court, subject of course, to appellate review." Id. at 33.