Does the Sixth Amendment right to counsel extend to a federal habeas corpus action filed by a state prisoner?

The Sixth Amendment right to counsel does not extend to federal habeas corpus actions filed by state prisoners. McCleskly v. Zant, 499 U.S. 467, 495 (1991). Petitioners do not have an absolute right to counsel for habeas corpus actions. Knaubert v. Goldsmith, 791 F.2d 722, 728 (9th Cir. 1986). Nevertheless, by statute, district courts have discretion to appoint counsel in habeas proceedings for "any person financially unable to obtain adequate representation" when "the interests of justice so require." 18 U.S.C.

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