Right to counsel
Washington provides for the appointment of counsel to indigent parents at all stages of a proceeding in which a child is alleged to be dependent, including termination of parental rights proceedings. Wash. Rev. Code § 13.34.090.2 This includes a right to counsel for non-consenting parents in private adoption proceedings where the prospective adoptive parent seeks to terminate parental rights of the natural parent. Wash. Rev. Code § 26.33.110(3)(b)(i). However, parents who voluntarily put their children up for adoption are not entitled to the appointment of counsel. In re Adoption of Hernandez, 607 P.2d 879 (Wash. Ct. App. 1980).