California, United States of America
The following excerpt is from Nicholson v. Mohamed, B238392 (Cal. App. 2012):
In Yarbrough v. Superior Court, supra, 39 Cal.3d 197, the defendant, acting in pro per., moved for appointment of counsel alleging that he was being sued for wrongful death; he was incarcerated, indigent, and uneducated; and he would suffer a default judgment as a result that could be avoided by appointment of counsel. The county contested the motion only insofar as the county might be required to compensate counsel. The court issued a peremptory writ of mandate directing the trial court to conduct further proceedings and consider, at a minimum, the defendant's indigency, the feasibility of a continuance, whether defendant's interests were actually at stake, and whether counsel would be helpful under the circumstances of the case.
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