The guardian ad litem uses independent judgment to determine the best interests of the child, whereas legal counsel advocates for the client what the client determines is in his own best interests. Although most states have statutes mandating representation for the child, the states vary concerning whether a guardian ad litem or legal counsel is required. Most arguments support the position that the child's representative should be legally trained. Little research on actual representation has been conducted, however, one report implies that even if children are being represented, the representation might be ineffective. There is a need for further study to determine whether representatives are actually being appointed and if the representatives are providing effective advocacy for children. 107 footnotes and appendix