In his article, "Why AFCs Should Not Be Appointed to Represent Non-Communicative Toddlers in Custody Disputes," Peter Galasso argues that an Attorney For the Child (AFC) should never be assigned to represent a toddler or, by implication, any non-verbal child. In taking this position, Galasso evinces a flawed understanding of the role of the attorney for the child and ignores the well-settled history of AFC advocacy for toddlers and newborns.

Galasso blames an "absence of guidance from the Appellate Division" for the failure of his argument to gain traction among judges. In fact, the real reason his argument has failed to gain traction is that the legislature, the Appellate Division, trial court jurists, and the chief judge have all recognized the tremendous value in assigning counsel to represent children of any age in family court and state Supreme Court matters.