Unlike in criminal proceedings, where defendants have a constitutionally guaranteed right to counsel, not all litigants in all civil proceedings have a right to counsel.
Instead the U.S. Supreme Court found a “presumption that an indigent litigant [in a civil proceeding] has a right to appointed counsel only when, if he loses, he may be deprived of his physical liberty.” In spite of this presumption, the due process clause “does not always require the provision of counsel in civil proceedings where incarceration is threatened,” such as civil contempt proceedings.