No right to counsel

Louisiana , Litigation , Parentage - Defendant/Respondent

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).

Appointment of Counsel: Other
Qualified: No
? If "yes", the established right to counsel or discretionary appointment of counsel is limited in some way, including any of: the only authority is a lower/intermediate court decision or a city council, not a high court or state legislature; there has been a subsequent case that has cast doubt; a statute is ambiguous; or the right or discretionary appointment is not for all types of individuals or proceedings within that category.