section. If the parent was previously represented by counsel from the Office of the Public Defender in a child abuse or neglect action filed pursuant to chapter 6 of Title 9 of the Revised Statutes on behalf of the same child, the same counsel, to the extent practicable, shall continue to represent the parent in the termination of parental rights action, unless that counsel seeks to be relieved by the court upon application for substitution of counsel or other just cause. Nothing in this section shall be construed to preclude the parent from retaining private counsel. In short, the right to counsel in a termination ease has constitutional as well as statutory bases. Either way, the performance of that counsel must be effective. See, e.g., V.F. v. State, 666 P.2d 42, 45 (Alaska 1983) (<HOLDING>); In re Trowbridge, 155 Mich.App. 785, 401
recognizing that a criminal defendants right to counsel is the right to the effective assistance of counsel holding because right to counsel is constitutionally guaranteed in parental termination proceeding effective assistance of counsel is also constitutionally required holding that a parents statutory right to counsel in termination proceedings guarantees the right to effective counsel recognizing that the statutory right to counsel in parental termination cases requires that the appointed counsel provide effective assistance holding that in parental termination proceedings the parent is entitled to effective assistance of counsel