Right to counsel

In State v. Creamer, 528 So. 2d 667, 668-69 (La. Ct. App. 1988), the Second Circuit found a right to counsel in a case involving a civil petition for child support "because the judgment rendered against the defendant wherein he was uncounseled was used as a basis to punish him for contempt."  The court relied on precedent from the Louisiana Supreme Court relating to criminal neglect where the court held that the right to counsel attaches in some predicate proceedings even where jail is not immediate possibility. The litigant in question had counsel for the actual contempt proceeding, although the authority for such was not cited.