In what circumstances will the court grant a parent's right to waive counsel in a termination action brought to terminate parental rights?

In view of the nature of the federal right it is not surprising that we have found no case holding the right to waive counsel in an acton brought to terminate parental rights is of constitutional dimension. Indeed under our state Constitution, there is no right to waive counsel in a criminal case. (See People v. Sharp (1972) 7 Cal.3d 448, 103 Cal.Rptr. 233, 499 P.2d 489; People v. McDaniel (1976) 16 Cal.3d 156, 127 Cal.Rptr. 467, 545 P.2d 843.) However, our legislature has made such a right available by statute in parental termination cases. (Civ.Code, 237.5.) ² As relevant to this [188 Cal.App.3d 1074] appeal, section 237.5 provides that when a parent appears without counsel and is unable to afford counsel, the court shall appoint an attorney to represent him or her, unless the parent knowingly and intelligently waives representation. (Id., subd. (b).)