the termination of parental rights filed pursuant to IR.J.SA. 30:4C — 15], the court shall provide the respondent parent with notice of the right to retain and consult with legal counsel. If the parent appears before the court, is indigent and requests counsel, the court shall appoint the Office of the Public Defender to represent the parent. The Office of the Public Defender shall appoint counsel to represent the parent in accordance with subsection c. of 65, 66 (1986) (explaining axiom that constitutional right to counsel includes right to competent counsel); see also In re M.S., 115 S.W.3d 534, 544 (Tex.2003) (finding statutory right to counsel in parental-rights termination eases embodies right to effective counsel); State ex rel. E.H., 880 P.2d 11, 13 (Utah Ct.App.1994) (<HOLDING>). III. We turn then to remedy. The ordinary
holding statute implicitly guaranteed appointed counsel for parents in termination proceedings be effective holding that a parents statutory right to counsel in termination proceedings guarantees the right to effective counsel holding that in parental termination proceedings the parent is entitled to effective assistance of counsel holding because right to counsel is constitutionally guaranteed in parental termination proceeding effective assistance of counsel is also constitutionally required recognizing that the statutory right to counsel in parental termination cases requires that the appointed counsel provide effective assistance