Since July 2011, indigent parents accused of abuse or neglect have had to manage the court system without an attorney. Recent legislative changes removed the statutory requirement contained in RSA 169-C:10, II(a) that counsel be appointed for requiring appointed counsel for indigent parents. However, the question still remains whether the parents have a constitutional right

New Hampshire has long recognized that a parent’s right to raise and care for one’s child is a fundamental constitutional right. In recognition of that right, there has been a statutory right to counsel for parent’s facing termination of parental rights proceedings and in abuse and neglect cases. In addition to the statutory authority, the New Hampshire