Does a parent have a constitutional right to competent counsel in a dependency proceeding?

A parent has a statutory right to competent counsel in dependency proceedings. ( 317.5, subd. (a).) Whether the parent has a constitutional right to competent counsel under the federal due process clause is determined on a case-by-case basis, after determining whether the balance of the private interests, the state's interests, and the risk that the procedure used will result in erroneous decisions overcomes the presumption against appointed counsel. (Lassiter v. Department of Soc. Serv. (1981) 452 U.S. 18, 27,

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