With no explanation, chose the best option from "A", "B", "C" or "D". of authority to justify a determination that the General Assembly intended to hinder a parent that way. Finally, this view harmonizes the right to waive counsel with similar rights in analogous cases. In Johnson v. Zerbst, 304 U.S. 458, 463 (1938), the United States Supreme Court recognized that the Sixth Amendment right to the assistance of counsel included the corresponding right to waive the assistance of counsel. Further more, a number of jurisdictions have accepted, in cases similar to the case at bar, a right to waive counsel in one form or another. See In re G.L.H., 614 N.W.2d 718 (Minn. 2000) (affirming trial court’s determination that parent had waived statutory right to counsel in action brought by county to terminate parental rights); In re Heller, 669 A.2d 25 (Del. 1995) (<HOLDING>); In re K.D.H., 871 S.W.2d 651 (Mo. Ct. App.

A: holding that the due process clause of the alaska constitution guarantees the right to effective counsel in proceedings for the termination of parental rights
B: holding that there was no procedural due process violation to allow mother to waive right to counsel and proceed pro se in a termination of parental rights case brought by delaware
C: holding that an ijs failure to obtain a knowing and voluntary waiver of the right to counsel from a pro se petitioner is a due process violation
D: holding that a defendant has a right to proceed pro se at trial
B.