Right to counsel

In Turner v. Whitsted, 327 Md. 106, 116, 607 A.2d 935, 940 (1992), the court noted that in a paternity action:

While [the child] is not a party to the action, Rule 2-423 permits the physical examination of a party or a 'person in the custody or under the legal control of a party.' Consequently, the court might even appoint counsel to represent [the child's] interests if it believes that those interests might be compromised by the blood test. If [the child's] best interests would be jeopardized by submitting to a blood test, the child's representative may then request a protective order.

The court did not cite any particular authority for such appointment for the child, which suggests the court was relying on its inherent power to appoint.