Does the Sixth Amendment have an absolute right to counsel in a habeas proceeding?

MultiRegion, United States of America

The following excerpt is from Munguia v. Robertson, Case No. 1:18-cv-00742-LJO-JDP (E.D. Cal. 2020):

Petitioner moved for the appointment of counsel, stating that he lacks the financial resources to obtain counsel and the legal knowledge to represent himself. ECF No. 9. A petitioner in a habeas proceeding does not have an absolute right to counsel. See Anderson v. Heinze, 258 F.2d 479, 481 (9th Cir. 1958) ("The Sixth Amendment has no application here . . . .").

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