Right to counsel

The WA Supreme court said there is a federal and state constitutional right to counsel in civil contempt cases as a matter of due process. Tetro v. Tetro, 544 P.2d 17, 19 (Wash. 1975).  According to the court in In re Custody of Halls, 109 P.3d 15, 21 (Wash. Ct. App. 2005), the Washington Supreme Court's decision in Tetro v. Tetro, 544 P.2d 17 (Wash. 1975), stands for the proposition that "In proceedings civil in form but criminal in nature, due process rights to liberty, the Sixth Amendment, and Washington Constitution article 1, section 22, require that a party threatened with jail be represented by counsel." 

It is unclear whether this opinion is still good law after the U.S. Supreme Court's decision in Turner v. Rogers (i.e. whether there is an independent state constitutional ground).

To see the documents from the case, check out the comprehensive bibliography page on Halls.