Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Not written by a barrister. The name was thought up by a second-year American law student sitting in a coffeehouse in Manhattan. Neither an authoritative statement of the law nor legal advice. Don't rely. Quick work.
Seventh Circuit: Nicole K. v. Terry Stigdon
A federal court should abstain from determining whether minors are categorically entitled to counsel in child-removal proceedings -- rather, denials in specific cases are subject to first review by the state's courts.