Discretionary appointment of counsel
The Oklahoma Supreme Court in Kiddie v. Kiddie, 563 P.2d 139 (Okla. 1977), stated: “A trial court may certainly appoint counsel to represent an indigent in a civil matter if it sees fit, but it is entirely discretionary.” 563 P.2d 139, 143 (Okla. 1977) (finding no right to appointed counsel for husband in divorce proceeding in which he represented himself pro se and was ultimately required to make alimony payments to former wife). However, it is not clear whether the court was referring to the court’s power to appoint counsel based on its inherent authority or pursuant to a case-by-case due process approach.