In Gideon 's Trumpet,' Anthony Lewis recounts the story of Clarence Gideon, an indigent man whose appeal to the United States Supreme Court improbably culminated with the Court holding that the right to counsel in a criminal trial was a fundamental right, one which requires the states to provide counsel to indigent criminal defendants. 2 Almost fifty years later in Turner v. Rogers,3 the Court rejected the analogous argument that the right to counsel in a civil contempt proceeding was a fundamental right where an indigent, noncustodial parent faces incarceration. This argument was at the core of the civil Gideon movement - one could hardly have imagined a better test case - and accordingly, the Court's adverse holding was a major blow. But many in that movement have held out hope, and not without good reason.
Chad Flanders & Alexander Muntges,
The Trumpet Player's Lament: Rethinking The Civil Gideon Movement,
U.D.C. L. Rev.
Available at: https://digitalcommons.law.udc.edu/udclr/vol17/iss1/5