Florida Supreme Court held that: The adversary nature of the proceeding, its complexity, the need for an evidentia-ry hearing, or the need for substantial legal research are all important ele ments which may require the appointment of counsel. This appointment authority is discretionary, with any doubts being resolved in favor of an indigent defendant. There is no absolute duty to appoint counsel for an indigent defendant. in a post-conviction relief proceeding unless the application on its face reflects a colorable or justiciable issue or -a meritorious grievance. The court has the authority to summarily deny relief without appointment of counsel when the petition and record reflect it is without merit. Graham, 372 So.2d at 1366; see also Russo v. Akers, 724 So.2d 1151, 1153 (Fla.1998)(<HOLDING>). While section 924.051(9) prohibits the use of
holding because right to counsel is constitutionally guaranteed in parental termination proceeding effective assistance of counsel is also constitutionally required holding on equal protection grounds that meaningful first appeal requires appointment of counsel for indigent defendants holding that when counsel is constitutionally mandated under weeks and graham section 9240519 does not prohibit or preclude appointment of counsel for indigent defendants in seeking collateral review holding that an indigent litigants right to appointed counsel has been recognized to exist only where she may be deprived of her physical liberty that the constitution does not require the appointment of counsel for indigent parents in every parentalstatus termination proceeding and that the decision whether due process calls for the appointment of counsel is to be answered in the first instance by the trial court subject to appellate review holding that the constitution does not require the appointment of two attorneys for indigent capital defendants