Read the following excerpt from a US court opinion:
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ch. 13, § 1, 2003 Tex. Gen. Laws 16 (codified at Tex.Code Crim. Proc. Ann. art. 64.01(c)). 3 .The Texas Supreme Court subsequently held that the statutory right to counsel in parental-rights termination cases includes the right to effective counsel. In re M.S., 115 S.W.3d 534, 544 (Tex.2003) ("we believe that '[i]t would seem a useless gesture on the one hand to recognize the importance of counsel in termination proceedings, as evidenced by the statutory right to appointed counsel, and, on the other hand, not require that counsel perform effectively’ ”). The supreme courts of several other states have examined statutes that provide a right to counsel and have held that the right to counsel entails that such counsel be effective. See Patchette v. State, 374 N.W.2d 397, 398 (Iowa 1985) ; Dunbar v. State, 515 N.W.2d 12, 14-15 (Iowa
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What is the most suitable continuation to the opinion? Your options are:
A. holding that the statutory right to counsel at a civil commitment hearing implicitly includes the right to the effective assistance of that counsel
B. recognizing that a criminal defendants right to counsel is the right to the effective assistance of counsel
C. holding that a parents statutory right to counsel in termination proceedings guarantees the right to effective counsel
D. holding that statutory grant of postconviction applicants right to courtappointed counsel in proceeding arising out of prison disciplinary hearings necessarily implies that that counsel be effective
E. recognizing constitutional right to effective counsel
Reply with [A, B, C, D, E] only.