The Court of Appeals of New York has held that an indigent parent faced with loss of a child's society, as well as the possibility of criminal charges, is entitled to assistance of counsel in child neglect proceedings and is required to be advised of such right.
In re Ella R.B., 30 N.Y.2d 352, 285 N.E.2d 288, 334 N.Y.S. 2d 133 (1972).
Infants - Child Neglect Proceeding,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol11/iss4/18