Right to counsel

In County of Los Angeles v. Superior Court, 162 Cal. Rptr. 636 (Ct. App. 1980), the county brought an action to establish an obligation, and the court cited to Salas v. Cortez, 593 P.2d 226 (Cal. 1979) (which found a state and federal constitutional right to counsel in paternity cases as a matter of due process) for the proposition that "the Supreme Court held that an indigent defendant in a paternity and child support action prosecuted by the district attorney is constitutionally entitled to appointment of free counsel to represent him. Accordingly, the county does not contest the appointment itself, but it contends that the court erred in ordering it to pay attorneys' fees ..." 

Then, in County of Ventura v. Tillett, 183 Cal. Rptr. 741 (Ct. App. 1982), disapproved of on other grounds, County of Los Angeles v. Soto, 35 Cal.3d 483, 674 P.2d 750 (Cal. 1984), the court of appeals held that an indigent mother was entitled to counsel in proceedings involving a stipulated judgment to pay child support. The Tillett court relied on County of Los Angeles to broadly hold, "[a]n indigent defendant in a child support action prosecuted by the district attorney under Welfare and Institutions Code section 11350 is constitutionally entitled to appointment of free counsel to represent him."

Subsequent to County of Los Angeles and Tillett, several courts suggested that a child support matter must be connected to a paternity action in order to trigger a right to counsel. See e.g. County of Orange v. Dabbs, 35 Cal. Rptr. 2d 79 (Ct. App. 1994) (finding right to counsel for appeal of order requiring father to reimburse welfare benefits paid to mother, where order was connected to paternity proceeding).