California, United States of America
The following excerpt is from Gonzalez v. Vargas, C041618 (Cal. App. 11/13/2003), C041618. (Cal. App. 2003):
"`California has recognized a number of situations in which an indigent litigant will be entitled to have counsel appointed. The most obvious example is that of an indigent criminal defendant. . . . In other cases the entitlement has been declared as a matter of procedural due process . . . , or established by statute, or both.' [Citation.] As a general rule, however, there is no due process right to counsel in civil cases." (People v. Madeyski (2001) 94 Cal.App.4th 659, 662.) Defendant has directed this court to no statute or other authority that would indicate she had a right to appointed counsel in this case.
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