Right to counsel

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Litigation, Incarceration for Fees/Fines (incomplete)

An intermediate court found a due process right to counsel for indigent litigants in civil contempt proceedings. Padilla v. Padilla, 645 P.2d 1327, 1328 (Colo. Ct. App. 1982).  It relied entirely on the threat to physical liberty, and did not clarify whether it was interpreting the state or federal constitution.  Although the case involved child support, the court spoke broadly about the right to counsel in all civil contempt proceedings.

It is uncertain whether it is still good law after the U.S. Supreme Court's decision in Turner v. Rogers.

Appointment of Counsel: categorical Qualified: yes