Right to counsel

In N.J. Div. of Youth & Family Servs. v. D.C., 571 A.2d 1295, 1299 (N.J. 1990), the New Jersey Supreme Court cited to Crist v. New Jersey Division of Youth & Family Services, 343 A.2d 815, 816 (N.J. Super. Ct. App. Div. 1975) (which found a constitutional due process right to counsel in termination of parental rights proceedings) for the proposition that "simple justice" requires appointment of counsel for proceedings giving temporary custody to the state via guardianship, as such proceedings "entail[] a cessation of visitation. That path leads to freeing the child for adoption."  Such a holding would provide a constitutional right to counsel in abuse/neglect proceedings as well.