In what circumstances will an indigent father be denied a Wende review if his appointed attorney cannot find any arguable issues?

In this respect, Salas v. Cortez (1979) 24 Cal.3d 22, 154 Cal.Rptr. 529, 593 P.2d 226, recognizing an indigent father's federal and state constitutional right to the appointment of counsel in a paternity action, becomes pertinent. Taking the arguments of Wende critics at face value, an indigent father in a paternity action would be entitled to Wende review if his appointed attorney could not find any arguable issues simply because he had a constitutional right to trial counsel. But an indigent father appealing the termination of parental rights in a dependency proceeding, who had a statutory right to counsel at trial, would not. There is no logic or justice in such disparate treatment between these indigent appellants.