In Adoption of Meghan (Jan 2012), the Massachusetts Supreme Judicial Court hedl both parents and children have a right to counsel in privately-initiated contested adoption proceedings.  The court noted that regardless of whether the petition is filed by the state or a private party, "the same fundamental, constitutionally protected interests are at stake, and the cost of erroneously terminating the parent's rights remains too high to require an indigent parent to risk it without counsel."  As to the child, the court noted the adoption is "of enormous consequence to the child" and that the child "cannot have a meaningful opportunity to be heard"  without counsel.