and custody proceedings — a subject in which “the states have an especially strong interest.” Phillips, Nizer, Benjamin, Krim & Ballon v. Rosenstiel, 490 F.2d 509, 516 (2d Cir.1973) (Friendly, J.). In particular, Falco challenges the State court’s order that he pay half the fees of the attorney appointed to represent his children in the divorce proceeding. Although there is some disagreement among New York courts about whether the fees for such court-appointed counsel should be borne by the public or by the parents, compare Redder v. Redder, 17 A.D.3d 10, 792 N.Y.S.2d 201, 204-05 (3d Dep’t 2005) (suggesting that the State should pay for a court-appointed attorney for the child in a custody proceeding), with Plovnick v. Klinger, 10 A.D.3d 84, 781 N.Y.S.2d 360, 363-66 (2d Dep’t 2004) (<HOLDING>), there is no discernible disagreement that
holding that courts may require one or both parents to pay for a courtappointed attorney for their children holding court could not require parents to divulge incriminating information but court could consider parents failure to undergo meaningful therapy in deciding whether parents could regain their children holding that it is plain error for a trial court to require a defendant to pay courtappointed attorney fees in the absence of legally sufficient evidence that defendant has the ability to pay the amount imposed recognizing fundamental right of parents to care for their children holding that it is in the interest of both parents and children that parents have ultimate authority to make medical decisions for their children unless neutral fact finder determines through due process hearing that parent is not acting in childs best interests