In re Interest of D.B.
Supreme Court of Florida
385 So. 2d 83 (1980)
In one dependency case, an indigent mother sought to reclaim custody of D.B. after surrendering her for adoption, while D.B.'s unmarried, incarcerated father had never legally recognized his paternity; the trial court appointed counsel for the father and a guardian ad litem for D.B. In a separate case, a 16-year-old mother who had abandoned her nine-month-old, D.S., faced only a temporary-custody proceeding, and the trial court similarly appointed counsel for the mother and a guardian ad litem for D.S. The state ordered to pay for both sets of appointed counsel appealed in both cases.
Must a court appoint counsel to represent an indigent parent in a child dependency proceeding if the parent is threatened with permanent loss of custody or if criminal charges may arise from the proceeding?