Right to counsel

Key_development Question_mark

Litigation, Child Support Enforcement (Civil Contempt)

In Brooks v. United States, 686 A.2d 214 (D.C. 1996), the court held that contemnors could not be incarcerated without first being appointed counsel, even in summary contempt situations. The court relied on a host of decisions from federal and state courts, as well as the Supreme Court's decision in Argersinger v. Hamlin, 407 U.S. 25 (1972), holding that "[a]pplying the Argersinger principle to civil and nonsummary criminal contempt reflects a recognition that 'any deprivation of liberty is a serious matter.'" 686 A.2d at 23. This decision is questionable after the U.S. Supreme Court's decision in Turner v. Rogers.

Appointment of Counsel: categorical Qualified: yes