Right to counsel

Key_development Question_mark

Litigation, Child Support Enforcement (Civil Contempt)

An intermediate court found a due process right to counsel for indigent litigants in civil contempt proceedings. It relied entirely on the threat to physical liberty, and did not clarify whether it was interpreting the state or federal constitution. It is uncertain whether it is still good law after the U.S. Supreme Court's decision in Turner v. Rogers.

Cite: Padilla v. Padilla, 645 P.2d 1327, 1328 (Colo. Ct. App. 1982)

Appointment of Counsel: categorical Qualified: yes