Discretionary appointment of counsel

In Walker v. Walker, 892 A.2d 1053, 1055 (Del. 2006), the Delaware Supreme Court stated that its reasoning from Watson v. Division of Family Services, 813 A. 2d 1101, 1108 (Del. 2002) and Hughes v. Div. of Family Services, 836 A.2d 498, 509 (Del. 2003), which held that the constitutional right to counsel in state-initiated termination and dependency cases is on a case-by-case basis, applies to private termination proceedings. Cf. Moore v. Hall, 62 A.3d 1203 (Del. Super. Ct. 2013) (in private termination case, court observes, “On a case-by-case basis, the Family Court properly and routinely finds that due process requires the appointment of counsel to represent parents who appear in a termination proceeding, request legal representation, and demonstrate indigency.”).