State, Dep't of Family Servs. v. Currier
Annotate this CaseIn 2008, the district court entered a default judgment and order establishing Father's paternity of a child and ordering him to pay child support. In 2011, the Department of Family Services (DFS) filed a petition for an order to show cause as to why Father should not be held in contempt of court for failing to pay child support. After Father requested counsel, the district court appointed counsel to represent Father. DFS objected to the court's order appointing counsel. The district court denied DFS's objection, ruling that due process required the state to provide an indigent party with counsel in a civil contempt proceeding for non-payment of child support when incarceration was one of the possible penalties. The Supreme Court reversed, holding that appointment of counsel was not required because Wyoming has sufficient substitute procedural safeguards to protect indigent obligors against the possibility of wrongful incarceration.
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