No right to counsel
In Franks v. Mercer, a decision coming down one week after Lassiter (but which did not mention Lassiter), the Court of Appeal of Louisiana, Second Circuit held that a parent in a paternity proceeding did not have a right to counsel:
No criminal consequences directly emanate from the judgment appealed. This action is not quasi-criminal in nature. We are not persuaded by defendant’s argument that he might later be subject to a contempt citation and imprisonment for failure to comply with the support order.
Franks v. Mercer, 401 So. 2d 470, 471-72 (La. Ct. App. 1981).