Right to counsel where custody is a “stage” of a dependency case
In In re Dependency of E.H., 243 P.3d 160 (Wash. Ct. App. 2010), a juvenile court granted concurrent jurisdiction to the family court to conduct non-parental custody proceedings, and the Court of Appeals found that the statutory right to counsel in dependency (Wash. Rev. Code § 13.34.090, Wash. Rev. Code § 13.34.062(2)(b)) extended to these custody proceedings since they were a “stage” of the dependency proceedings.