Right to counsel

Two appellate courts have held there is a right to counsel in stepparent adoption cases.  See In re Jay, 197 Cal. Rptr. 672 (Cal. Ct. App. 1983) (indigent noncustodial parent accused of neglect has due process right to appointed counsel in stepparent adoption proceeding); Appellate Defenders, Inc. v. Cheri S. 42 Cal.Rptr.2d 195, 199(Cal. App. 1995) (finding indigent parent entitled to counsel where parent's custody/control rights have been terminated or consent found unnecessary in stepparent adoption proceeding, but not making clear whether right based on due process, equal protection, or statutory interpretation).