The following excerpt is from Gonzales v. Bitter, 1:12-cv-00714-BAM (HC) (E.D. Cal. 2012):
4. The Sixth Amendment's right to counsel does not apply in habeas corpus actions. See Knaubert v. Goldsmith, 791 F.2d 722, 728 (9th Cir. 1986). Under 18 U.S.C. 3006A(a)(2)(B), however, a district court is authorized to appoint counsel to represent a habeas petitioner whenever "the court determines that the interests of justice so require" and such person is financially unable to obtain representation.
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