On the fiftieth anniversary of Gideon v Wainwright,' many scholars are examining 2 the promise to not ration justice 3 by requiring counsel to be appointed for the indigent for State crimes. 4 Yet, other scholars are trying to expand Gideon's promise to all civil law matters,5 including immigration. Providing free appointed immigration counsel for representation in secretive 7 civil immigration removal proceedings would be ideal. However, for respondents who are subjected to the mandatory deportation consequences of their *9. convictions, immigration representation is impractical and serves little purpose.' 0 A better approach is to have criminal counsel simultaneously provide immigration representation by creating a record of conviction to avoid removal proceedings in their entirety.
Maurice Hew Jr.,
Expanding The Civil Privilege Of Being Represented By Counsel Through The Presumed Prejudice Doctrine,
U.D.C. L. Rev.
Available at: https://digitalcommons.law.udc.edu/udclr/vol17/iss1/6