The Fifth DCA (motto: Last but Not Least!) has ruled as follows:
Indigent parents get court-appointed counsel in private chapter 39 TPR cases. T.M.W. v. T.A.C., — So.3d —-, 2012 WL 591671 (Fla. 5th DCA 2012).
Failure to follow ICWA may be raised for the first time on appeal. G.L. v. DCF, — So.3d —-, 2012 WL 511444 (Fla. 5th DCA 2012).