California, United States of America
The following excerpt is from The People v. Englebrecht, 106 Cal.Rptr.2d 738, 88 Cal.App.4th 1236 (Cal. App. 2001):
In Iraheta v. Superior Court (1999) 70 Cal.App.4th 1500, the issue was whether there is a constitutional right to the appointment of counsel in actions, like the present one, to enjoin gang activity in a specified target area. The court first noted that in general the right to the appointment of counsel exists in civil cases only where a litigant's physical liberty may be lost. (Id. at p. 1503.)
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