[¶ 22] As the trial court correctly noted, we have not yet addressed the standard that will apply in assessing a parent's claim of ineffective assistance of counsel in termination of parental rights proceedings. See In re S.P., 2013 ME 81, ¶ 10 n. 4, 76 A.3d 390. Courts in other jurisdictions that recognize a parent's right to the effective assistance of counsel in termination proceedings have generally applied one of two very similar standards.[¶ 23] The first is the same standard used in criminal cases, which was first announced in Strickland v. Washington, 466 U.S. 668, 104 S.Ct. 2052, 80 L.Ed.2d 674. The Strickland standard is a two-part test for determining ineffectiveness in the criminal context:

In Wetherhorn v. Alaska Psychiatric Institute, in the context of a civil commitment proceeding, we discussed the reasons for declining direct review under these circumstances:See, e.g., K.H. v. Jefferson Cnty. Dep't of Human Res., 106 So.3d 420, 423 (Ala.Civ.App.2012) ; Porta v. Arkansas Dep't of Human Servs., 2014 Ark. App. 16, 431 S.W.3d 383, 387 (2014) ; In re Marriage of Stephen P., 213 Cal.App.4th 983, 153 Cal.Rptr.3d 154, 161 (2013) ; L.H. v. Dep't of Children & Families, 995 So.2d 583, 584–85 (Fla.Dist.App.2008) ; In re S.D., 671 N.W.2d 522, 530 (Iowa App.2003) ; In re S.P., 76 A.3d 390, 394 n. 4 (Me.2013) ; In re Oleg, 776 N.E.2d 1039 (Mass.App.2002) ; Matter of the Welfare of J.M.K.A., Child, No. Co–97–1156, 1997 WL 770399, at *3 (Minn.App. Dec. 16, 1997) ; Matter of C.C., 907 P.2d 241, 244–45 (Okla.Civ.App.1995) ; Interest of M.D.(S)., 168 Wis.2d 995, 485 N.W.2d 52, 55–56 (1992).[I]t is difficult for an appellate court to review a claim of ineffective assistance of counsel unless a record has been developed that includes findings of facts and conclusions of law regarding the claim.