Right to counsel
Litigation, Civil Commitment
In Tetro v. Tetro, 544 P.2d 17, 19 (Wash. 1975), the Washington Supreme Court stated that "In proceedings civil in form but criminal in nature -- such as ... mental commitment hearings -- representation is clearly part of due process," and cited to Heryford v. Parker, 396 F.2d 393 (10th Cir. 1968) and Lessard v. Schmidt, 349 F. Supp. 1078 (E.D. Wis. 1972). But as Tetro did not involve civil commitment, its statement was dicta.
Appointment of Counsel:
categorical
Qualified:
yes
