The following excerpt is from Madera v. Board of Education of City of New York, 386 F.2d 778 (2nd Cir. 1967):
The trial court seemed to think that once due process requires a hearing, the right to representation by counsel follows automatically. In support of this conclusion, it cites Powell v. State of Alabama, 287 U.S. 45, 53 S.Ct. 55, 77 L.Ed. 158 (1932).
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