Does a defendant have a state constitutional right to counsel in post-judgment criminal proceedings?

Indeed, "[a]t common law, appellate review of a criminal conviction, regardless of how grave the offense, was not viewed as a necessary component of elementary due process" ( People v. Romero , 7 N.Y.3d 633, 636, 826 N.Y.S.2d 163, 859 N.E.2d 902 [2006] ).

In interpreting our state's constitutional right to counsel, we have stated that

[32 N.Y.3d 311]

In certain postconviction accusatory proceedings, we have held "the right to counsel is required because the outcome liberty or imprisonment depends upon an arbiter's determination as to the truth of assertions" affecting defendant's status ( People v. Garcia , 92 N.Y.2d 726, 730, 685 N.Y.S.2d 919, 708 N.E.2d 992 [1999] ). We have never held that a defendant is entitled to a state constitutional right to counsel in all postjudgment criminal proceedings.