Right to counsel

In In re Marriage of Stariha, 509 N.E.2d 1117 (Ind. Ct. App. 1987), the court found a Fourteenth Amendment right to counsel in cases involving contempt for failure to pay child support, due to the risk of incarceration.

It also found sufficient state action at play, despite the contempt having been filed by an individual:

It is difficult to imagine how the present case does not involve state action. Admittedly, Rebecca initiated this action as a private individual. However, the trial court found John in contempt for failure to pay child support pursuant to Rebecca's motion and sentenced him to thirty days. Certainly, John's incarceration, depriving him of his physical liberty for thirty days, amounted to state action. The court enforced a contempt proceeding that was initiated privately ... Here, there is a definite nexus between Rebecca's complaint for failure to pay child support and the trial court's finding of contempt and incarceration of John for the same activity.

While Stariha is an unpublished opinion and such opinions have no precedential value in Indiana, it has been subsequently relied upon by another court.  In Moore v. Moore, 11 N.E.3d 980 (Ind. Ct. App. 2014), a case that came after Turner v. Rogers, 564 U.S. 431 (2011) (no right to appointed counsel under Fourteenth Amendment in civil contempt cases, at least where private party initiates contempt), the court, without mentioning Turner at all, relied on Stariha for the right to appointed counsel for child support contempt and Marks v. Tolliver, 839 N.E.2d 703, 706 (Ind. Ct. App. 2005) for the proposition that the right attaches even where a private person initiates the contempt.