At present, hundreds of impoverished parents appear unrepresented in civil actions because they cannot afford counsel. The courts, not wishing to impose significant expenses on the counties in which they sit, have yet to recognize a constitutional right to counsel in critical civil actions affecting the family. These decisions do not reconcile with the fundamental rights to parent and to have the state not interfere with the child-parent relationship. As a result of the current inequities, indigent parent-victims of domestic violence often lose custody of their children simply because they cannot afford a lawyer. This article argues the right to counsel should be extended to child custody disputes to level the playing field where only one parent, often the abusive partner, can afford counsel. The Court must decide whether the constitutions of various states provide a remedy for the widespread inequities created in part by the drastic diminution of available free and low-cost legal services. Providing impoverished victims of violence representation in their custody disputes is a necessary first step. The efforts to meet the needs of those who cannot afford an attorney are obstructed by drastic reductions in available resources. Civic and legal aid organizations cannot be the strangers on which low income litigants rely.