7-25-07 (A-76-06)
Parents who are the subject of a termination action have the
right to effective counsel. A claim of ineffective assistance
of counsel is to be evaluated in light of the standard
articulated by the United States Supreme Court in Strickland v.
Washington, 466 U.S. 668 (1984). Such a claim must be raised on
the parent’s direct appeal from an order of termination.
