The Due Process Clauses of the Ohio and United States Constitutions do not guarantee an indigent parent the right to appointed counsel at a civil-contempt purge hearing involving nonpayment of child-support obligations; parent’s interest in personal liberty is diminished by time of purge hearing because parent’s continued freedom has been conditioned on compliance with purge requirements, it is highly unlikely that purge hearing will result in an erroneous decision, and government has strong interest in ensuring that parents financially support their children and in resolving those matters as quickly as possible.
Laura Morgan is a Family Law Consultant. Laura is available for consultation, brief writing and research on family law issues throughout the country. She can be reached through her website. www.famlawconsult.com