California, United States of America
The following excerpt is from Borror v. Department of Investment, 15 Cal.App.3d 531, 92 Cal.Rptr. 525 (Cal. App. 1971):
2 This case was decided after Gideon v. Wainwright (1963) 372 U.S. 335, 83 S.Ct. 792, 9 L.Ed.2d 799, which holds that in criminal cases an indigent defendant has the constitutional right to counsel.
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