Letesheia O. v. State, Division of Child & Family Services

*381OPINION

By the Court,

Parraguirre, J.:

In considering this appeal, we necessarily examine when a constitutional right to counsel exists in the context of a parental rights termination proceeding, for without this constitutional right, no ineffective-assistance-of-counsel claim will lie. We conclude that the right to counsel must be assessed on a case-by-case basis, consistent with the United States Supreme Court’s decision in Lassiter v. Department of Social Services.1 As no right to counsel exists in this case, we do not reach the claim of ineffective assistance of counsel.

FACTS

Appellant…