are based in part on history and tradition. Michael H. v. Gerald D., 491 U.S. 110, 105 L. Ed. 2d 91 (1989). Therefore, prior cases of this Court are instructive on the issue before us because they show how we have addressed custody issues in a wide variety of circumstances. North Carolina law traditionally has protected the interests of natural parents in the companionship, custody, care, and control of their children, with similar recognition that some facts and circumstances, typically those created by the parent, may warrant abrogation of those interests. The reasoning for such a rule was, perhaps, best explained in In re Hughes, 254 N.C. 434, 436-37, 119 S.E.2d 189, 191 (1961), in which this Court stated that parents have a duty to care for their minor c 2 U.S. 18, 68 L. Ed. 2d 640 (<HOLDING>). However, the United States Supreme Court has
holding that the due process clause of the alaska constitution guarantees the right to effective counsel in proceedings for the termination of parental rights holding that although petitioners dueprocess rights were not violated under the circumstances of that case in some cases due process would require appointment of counsel in a decision to terminate parental status holding that in a proceeding to terminate parental rights the preponderance of the evidence standard of proof violates the due process clause and that due process requires at least a clear and convincing evidence standard holding that the clear and convincing standard provides appropriate due process in cases involving parental rights 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