Right to counsel
A lower court extended 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 right to counsel for parents in termination proceedings ,and which was cited with approval for the New Jersey Constitution by the New Jersey Supreme Court in Pasqua v. Council, 892 A.2d 663, 674 n.5 (N.J. 2006) and N.J. Div. of Youth & Family Servs. v. B.R., 929 A.2d 1034,1036 (N.J. 2007)) to provide a right to appointed counsel for children in dependency or termination proceedings. N.J. Div. of Youth & Family Servs. v. Wandell, 382 A.2d 711, 713 (N.J. Juv. & Dom. Rel. Ct. 1978) (finding right under both state and federal constitutions; “[s]urely if due process required that a mature adult subjected to these proceedings requires the assistance of able counsel, no less should be required to protect the interests of a minor incapable of speaking for himself.”).
Wandell was subsequently cited with approval (albeit in a case where a child was appointed counsel pursuant to statute) in Matter of Adoption of a Child by E.T., 695 A.2d 734 (N.J. Super. Ct. App. Div. 1997).
