When relative strangers who had briefly cared for her son sued for custody, Deborah Frase faced a reality all-too-familiar to low-income Americans: representing herself in court. Unable to find a free lawyer and denied appointed counsel, Frase argued the case herself and won custody, but the court imposed several conditions. She appealed to Maryland’s Court of Appeals, claiming that she had a right to appointed counsel under the state constitution. The majority in a 4-to-3 decision sidestepped the issue. In a strong concurring opinion, however, three justices powerfully argued for a constitutional right to counsel in certain civil cases, noting that “this issue will not go away.” Only one vote shy of making legal history, the Frase decision is the closest any court has come to affirming a civil right to counsel.