Id. at 208 n. 30, 97 S.Ct. 2569 (citing Roger J. Traynor, Is This Conflict Really Necessary ?, 37 Tex. L.Rev. 657, 660-61 (1959)). Thus, the Court has acknowledged that the status exception comports with due process requirements when properly applied even though the defendant lacks minimum contacts with the forum. “Given that the United States Supreme Court has consistently recognized that certain types of cases involving status may not offend the Fourteenth Amendment, we must decide whether the status exception extends to parental termination proceedings. We conclude that it does for three reasons. First, parental termination proceedings clearly involve the determination of a child’s status vis-a-vis its parents. See In re Interest of M.L.K, 13 Kan.App.2d 251, 768 P.2d 316, 319 (1989) (<HOLDING>); In re M.S.B., 611 S.W.2d 704, 706
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 the status exception extends to termination proceedings because the tjermination of parental rights is nothing more than a determination of the legal status between the natural parent and the child holding that in parental termination proceedings the parent is entitled to effective assistance of counsel holding that although samesex partner may have been able to prove her status as a de facto parent such status was not sufficient to establish parental rights to custody and visitation over the objection of the biological mother holding the parental rights of a child may not be terminated unless that parent has been represented by counsel at every critical stage of the proceedings