Discretionary appointment of counsel
Indigent parents of Indian children are entitled to an attorney in termination of parental rights cases. Nev. Rev. Stat. § 128.023(2); see also § 62D.210(2) (as to proceedings involving placement into foster care). As to all other parents though, appointment is merely discretionary, Nev. Rev. Stat. § 128.100(2), subject to the due process balancing test used by the U.S. Supreme Court in Lassiter. See In re Parental Rights as to N.D.O., 115 P.3d 223 (Nev. 2005). An abuse of discretion standard is applied on appeal. See id.